Exam 10: Special Partnership Issues

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Identify which of the following statements is true.

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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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Marc is a calendar-year taxpayer who owns a 30% capital and profits interest in the MN Partnership.Nancy sells the remaining 70% capital and profits interest to Henry on October 31.The partnership year-end is March 31 as permitted by the IRS for business purpose reasons.The MN Partnership

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A partnership terminates for tax purposes

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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.

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If a partnership chooses to form an LLC,under the check-the-box rules,and assuming no elections are made,the entity will be taxed as

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Steve sells his 20% partnership interest having a $28,000 basis to Nancy for $40,000 cash.At the time of the sale,the partnership has no liabilities and its assets are as follows: Steve sells his 20% partnership interest having a $28,000 basis to Nancy for $40,000 cash.At the time of the sale,the partnership has no liabilities and its assets are as follows:   The receivables and inventory are Sec.751 assets.There is no agreement concerning the allocation of the sales price.Steve must recognize The receivables and inventory are Sec.751 assets.There is no agreement concerning the allocation of the sales price.Steve must recognize

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

(True/False)
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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?

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On December 31,Kate receives a $28,000 liquidating distribution from the KLM Partnership.On that date,Kate's basis in her limited partnership interest is $18,000 (which,of course,includes her share of partnership liabilities).The other partners assume her $6,000 share of liabilities.Just prior to the distribution,the partnership has the following balance sheet.Kate is leaving the partnership but the partnership is continuing. On December 31,Kate receives a $28,000 liquidating distribution from the KLM Partnership.On that date,Kate's basis in her limited partnership interest is $18,000 (which,of course,includes her share of partnership liabilities).The other partners assume her $6,000 share of liabilities.Just prior to the distribution,the partnership has the following balance sheet.Kate is leaving the partnership but the partnership is continuing.         What is the amount and character of the gain that Kate must recognize on the liquidating distribution? On December 31,Kate receives a $28,000 liquidating distribution from the KLM Partnership.On that date,Kate's basis in her limited partnership interest is $18,000 (which,of course,includes her share of partnership liabilities).The other partners assume her $6,000 share of liabilities.Just prior to the distribution,the partnership has the following balance sheet.Kate is leaving the partnership but the partnership is continuing.         What is the amount and character of the gain that Kate must recognize on the liquidating distribution? What is the amount and character of the gain that Kate must recognize on the liquidating distribution?

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When Rachel's basis in her interest in the RST Partnership is $40,000,she receives a current distribution of office equipment.The equipment has an FMV of $60,000 and a basis of $50,000.Rachel will not use the office equipment in a business activity.What tax issues should Rachel consider with respect to the distribution?

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Susan contributed land with a basis of $6,000 and an FMV of $10,000 to the SH Partnership two years ago to acquire her partnership interest.This year,the land is distributed to Harry when its FMV is $11,000.No other distributions have been made since Susan became a partner.When the land is distributed,the partnership's basis in the land immediately before distribution is increased by

(Multiple Choice)
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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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For purposes of Sec.751,inventory includes all of the following except

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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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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: 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:         What are the amount and character of the gain that Kate must recognize on the sale? 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:         What are the amount and character of the gain that Kate must recognize on the sale? What are the amount and character of the gain that Kate must recognize on the sale?

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Identify which of the following statements is true.

(Multiple Choice)
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David sells his one-third partnership interest to Diana for $60,000 when his basis in the partnership interest is $48,000.On the date of sale,the partnership has no liabilities and the following assets: David sells his one-third partnership interest to Diana for $60,000 when his basis in the partnership interest is $48,000.On the date of sale,the partnership has no liabilities and the following assets:    The building is depreciated on a straight-line basis.What tax issues should David and Diana consider with respect to the sale transaction? The building is depreciated on a straight-line basis.What tax issues should David and Diana consider with respect to the sale transaction?

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