What are the tax consequences under McDougal and general tax principles to the AB LLC on the receipt of Charlie's legal services in exchange for admitting Charlie to the partnership as a one-third partner with a $400,000 capital account? How would the answer change if instead the 2005 Proposed Regulations determine the tax consequences?
(a) change if Avery and Blair hold Black acre as joint tenants in an arrangement that is not treated as a partnership and then create an LLC with Charlie? Avery and Blair contribute their joint tenancy interest in Black acre for a one-third interest each. Charlie receives a one- third interest in the LLC in exchange for his legal services.  
(b) What are the tax consequences under McDougal and general tax principles to the AB LLC on the receipt of Charlie's services in exchange for admitting Charlie to the partnership as a one-third partner with a $600,000 capital account? How would the answer change if instead the 2005 Proposed Regulations determine the tax consequences?

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a Under McDougal and general tax principles the tax consequences to the AB LLC on the receipt of Cha... View the full answer