Exam 10: Special Partnership Issues

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Identify which of the following statements is true.

(Multiple Choice)
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Under Sec. 751, unrealized receivables include potential Section 1245 or 1250 recapture on the partnership's depreciable property.

(True/False)
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The XYZ Partnership owns the following assets on December 31: The XYZ Partnership owns the following assets on December 31:   By how much must XYZ reduce its unrealized receivables to avoid meeting the substantially apprec inventory test? By how much must XYZ reduce its unrealized receivables to avoid meeting the substantially apprec inventory test?

(Multiple Choice)
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The limited liability company (LLC) has become a popular business form because of its limited liability protection for its owner. The S corporation also provides limited liability protection for its owner. What advantages does an LLC provide that are not available with an S corporation?

(Essay)
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Under the check- the- box rules, an LLC with more than one member is taxed as a partnership unless it elects to be taxed as a corporation.

(True/False)
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A partnership cannot recognize a gain or loss on a current distribution.

(True/False)
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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

(Multiple Choice)
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The Tandy Partnership owns the following assets on December 31: The Tandy Partnership owns the following assets on December 31:   Is the partnership's inventory considered to be substantially appreciated for purposes of Sec. 751? Show your work. Is the partnership's inventory considered to be substantially appreciated for purposes of Sec. 751? Show your work.

(Essay)
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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?

(Multiple Choice)
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Do most distributions made by a partnership require a Sec. 751 calculation?

(Essay)
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Identify which of the following statements is false.

(Multiple Choice)
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Rod owns a 65% interest in the RRR Partnership, a general partnership, which he sells to the two remaining partners - Roger and Regis. The three partners have agreed that Rod will receive $160,000 in cash from the sale. Rod's basis in the partnership interest before the sale is $125,000, which includes his $35,000 share of partnership recourse liabilities. The partnership has assets with a $310,000 FMV and a $210,000 adjusted basis. What issues should Rod, Roger, and Regis consider before this sale takes place?

(Essay)
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What are the advantages of a firm being formed as a limited liability company (LLC) instead of as a limited partnership?

(Essay)
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What is an electing large partnership? What are the advantages to the partnership of electing to be taxed under the electing large partnership rules?

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The Principle Limited Partnership has more than 300 partners and is publicly traded. The Principle was grandfathered under the 1987 Tax Act and has consistently been taxed as a partnership. In the current year, The Principle Limited Partnership will continue to be very profitable and will continue to pay out about 30% of its income to its owners each year. The managing partners of The Principle want to consider the firm's options for taxation in the current and later years.

(Essay)
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A limited liability company is a form of business entity that combines the legal benefits of the corporate form with the tax benefits of the partnership form.

(True/False)
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Sally is a calendar- year taxpayer who owns a 30% capital and profits interest in the SEM Partnership. Eric sells the remaining 70% capital and profits interest to Michelle on October 3. The partnership year- end is March 31 as permitted by the IRS for business purposes. Which of the following statements is correct?

(Multiple Choice)
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Jerry has a $50,000 basis for his interest in JJ Partnership before receiving a current distribution consisting of $8,000 in money, accounts receivable having a zero basis to the partnership, and land having a $28,000 basis to the partnership. What will Jerry's basis be in these assets?

(Essay)
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What is the definition of "substantially appreciated inventory"?

(Multiple Choice)
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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 ordinary income to its partners?

(Multiple Choice)
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