Exam 10: Special Partnership Issues

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A partnership terminates for federal income tax purposes if

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What are some advantages and disadvantages of making a Section 754 election?

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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 LM Partnership terminates for tax purposes on July 15 when Latasha sells her 60% capital and profits interest to Zoe for $100,000.The partnership has no liabilities,and its assets at the time of termination are as follows: The LM Partnership terminates for tax purposes on July 15 when Latasha sells her 60% capital and profits interest to Zoe for $100,000.The partnership has no liabilities,and its assets at the time of termination are as follows:   Marika,a 40% partner in the LM Partnership,has a $64,800 basis in her partnership interest (outside basis)at the time of the termination.She has held her LM Partnership interest for three years at the time of the termination.The bases of Marika and Zoe in the new LM Partnership is: Marika,a 40% partner in the LM Partnership,has a $64,800 basis in her partnership interest (outside basis)at the time of the termination.She has held her LM Partnership interest for three years at the time of the termination.The bases of Marika and Zoe in the new LM Partnership is:

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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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A partnership cannot recognize a gain or loss on a current distribution.

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On November 30,Teri received a current distribution of cash of $4,000,marketable securities with a basis of $24,000 and an FMV of $30,000,and inventory with a basis of $2,000 and an FMV of $6,000.Prior to the distribution,Teri's basis in her interest in the partnership was $30,000.(There is no Sec.751 exchange as a result of the distribution. )How much gain (if any)must Teri recognize as a result of the distribution?

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If a distribution occurs within ________ years of the contribution date,in a nonliquidating distribution that does not qualify for Sec.751 treatment,the distribution event may trigger a precontribution gain or loss.

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What is the definition of "substantially appreciated inventory"?

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When a retiring partner receives payments that exceed the value of that partner's partnership property,the excess payment is a guaranteed payment.

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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?

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The definition of "inventory" for purposes of Sec.751 includes

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Identify which of the following statements is true.

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Do most distributions made by a partnership require a Sec.751 calculation?

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Mirabelle contributed land with a $5,000 basis and a $9,000 FMV to MS Partnership four years ago.This year the land is distributed to Sergio,another partner in the partnership.At the time of distribution,the land had a $12,000 FMV.How much gain should Mirabelle and Sergio recognize?

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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.

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What is the character of the gain/loss on the sale of a partnership interest?

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The sale of a partnership interest always results in capital gain or loss rather than ordinary income.

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Can a partner recognize both a gain and a loss on the sale of a partnership interest? If so,under what conditions?

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Eicho's interest in the DPQ Partnership is terminated when her basis in the partnership is $70,000.She receives a liquidating distribution of $20,000 cash and inventory with a $24,000 basis and a $40,000 FMV.What is her gain or loss,and what is her basis in the inventory received?

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