Exam 10: Special Partnership Issues

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A partner's holding period for property distributed as a current distribution begins on the date of distribution.

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Patrick purchases a one-third interest in the PPP partnership for $600,000.The partnership has assets with a value of $1,500,000.PPP has a 754 election in effect.What is the amount of the basis adjustment?

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On December 31,Kate sells her 20% interest (with a basis of $18,000 which,of course,includes a share of partnership liabilities)in the KLM Partnership to Karl for $27,000 cash plus assumption of her $6,000 share of liabilities.On that date,the partnership has the following balance sheet: Assets Basis Fair Market Value Cash \ 30,000 \ 30,000 Accounts receivable 0 20,000 Inventory 15,000 25,000 Land Total \ 90,000 \ 165,000 Equities Basis Fair Market Value Notes payable \ 30,000 \ 30,000 Kate, capital 12,000 27,000 Lynn, capital 24,000 54,000 Mark, capital \ 54,000 Total \ 90,000 \ 165,000 What are the amount and character of the gain that Kate must recognize on the sale?

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 Total  Sec. 751 Assets  Other  Amount realized $33,000$9,000$24,000 Minus: adjusted (18,000(3,000)(15,000) basis $15,000$6,000$9,000 Recognized gain  Ordinary  Capital  Character of gain \begin{array} { | l | c | c | c | } \hline & \text { Total } & \text { Sec. 751 Assets } & \text { Other } \\\hline \text { Amount realized } & \$ 33,000 & \$ 9,000 & \$ 24,000 \\\text { Minus: adjusted } & (18,000 & (3,000) & (15,000) \\\text { basis } & \$ 15,000 & \$ 6,000 & \$ 9,000\\\text { Recognized gain }&&\text { Ordinary }&\text { Capital }\\\text { Character of gain }\\\hline\end{array}

A partnership terminates for tax purposes

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Identify which of the following statements is true.

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The total bases of all distributed property in the partner's hands following a nonliquidating distribution is limited to

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Tony sells his one-fourth interest in the WindyCity Partnership to Bill for $100,000 cash when the partnership's assets are as follows: Assets Basis Fair Market Value Cash \ 80,000 \ 80,000 Unrealized receivables 0 72,000 Inventory 80,000 184,000 Land Total \ 400,000 The partnership has no liabilities on the sale date.Tony's basis in his partnership interest on the date of the sale is $60,000.What is the allocation of Tony's gain to the assets received?

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The AB,BC,and CD Partnerships merge into the ABCD Partnership.AB (owned by Austin and Ben)contributes assets worth $100,000.BC (owned by Ben and Charlie)contributes assets worth $200,000.CD (owned by Charlie and Dennis)contributes assets worth $300,000.The capital and profits interest in ABCD is owned by: Austin,10%; Ben,30%; Charlie,25%; and Dennis,35%.ABCD Partnership is a continuation of

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Becky has a $24,000 basis in her partnership interest.She receives a current distribution of $4,000 cash,unrealized receivables with a basis of $12,000 and an FMV of $16,000,and land held as an investment with a basis of $3,000 and an FMV of $8,000.The partners' relative interests in the Sec.751 assets do not change as a result of the current distribution.The basis of her partnership interest following the distribution is

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The AB Partnership has a machine with an FMV of $25,000 and a basis of $20,000.The partnership has taken an $8,000 depreciation on the machine.The unrealized receivable related to the machine is

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Patrick purchased a one-third interest in the PPP partnership for $600,000.At the time of the purchase,the partnership had a 754 election in effect and its only asset was land with a basis of $1,500,000.This year,PPP sells the land for $1,800,000.What is Patrick's recognized share of the gain on the sale of the land?

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A partner's holding period for a partnership interest is never considered when determining the holding period for property distributed in a liquidating distribution.

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Tenika has a $10,000 basis in her interest in the TF Partnership and no remaining precontribution gain immediately before receiving a current distribution that consisted of $4,000 in money,plastic tubes held in inventory with a $3,000 basis to the partnership and an FMV of $3,375,and drip irrigation pipe held as inventory with a $6,000 basis to the partnership and an FMV of $5,000.What is Tenika's basis for the plastic tubes and drip irrigation pipe?

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Ted King's basis for his interest in the Troy Partnership is $24,000.In complete liquidation of his interest,King receives cash of $4,000 and real property (not a Sec.751 asset)having an FMV of $40,000.Troy's adjusted basis for this realty is $15,000.Section 736 does not apply.King's basis for this realty is

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The STU Partnership,an electing Large Partnership,has no passive activities and reports the following transactions for the year: net long-term capital losses $50,000,Sec.1231 gain $60,000,ordinary income $20,000,charitable contributions $15,000,and tax-exempt income $2,000.How much will be reported as long-term capital gains to its partners?

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Carlos has a basis in his partnership interest of $30,000.He receives a current distribution of $6,000 cash,unrealized receivables (FMV $11,000,basis $10,000),inventory (FMV $8,000,basis $4,000),land held as an investment (FMV $7,000,basis,$6,000),and building (FMV $21,000,basis $9,000).The partners' relative interests in the Sec.751 assets do not change as a result of the current distribution.Carlos's basis in the building is

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When must a partnership make mandatory basis adjustments?

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If a partnership asset with a deferred precontribution gain is distributed within seven years of acquisition in a nonliquidating distribution to a partner who did not contribute the asset,the precontribution gain must be recognized by the contributing partner.

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A partnership terminates for federal income tax purposes if

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The XYZ Partnership owns the following assets on December 31: Basis FMV Cash \ 20,000 \ 20,000 Unrealized receivables 0 15,000 Inventory \ 30,000 35,000 Land (Sec. 1231 asset) 40,000 70,000 By how much must XYZ reduce its unrealized receivables to avoid meeting the substantially appreciated inventory test?

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