For each of the following independent fact patterns, indicate whether a termination of the partnership has occurred for tax purposes. Assume that no other partnership interests are sold either one year before or one year after the transactions described.
a. Paige sells her interest in capital and profits of the PQR Partnership. She owns a 48% interest in capital and a 60% interest in the partnership's profits.
b. Ryan and Rob are equal partners in the R & R Partnership. Ryan dies on January 15, 2017. Rob purchases Ryan's interest from his estate on March 15, 2017. Answer for January 15, 2017.
c. Answer part (b) for March 15, 2017.
d. Joel, a 52% partner in the profitable J & D Partnership, gives his entire interest to his son on July 1, 2017.
e. Jessica sells her 50% interest in the FJK Partnership to new partner Ashley.
f. Carol, Cora, and Chris are equal partners in the Canary Partnership. On January 22, 2017, Cora sells her entire interest to Ted. On December 29, 2017, Carol sells a 15% interest to Earl. On January 25, 2018, Chris sells his interest to Frank.