Question
1. If a partner contributes appreciated property to a partnership, and the partnership later sells the property, how will the deferred gain be allocated between
1. If a partner contributes appreciated property to a partnership, and the partnership later sells the property, how will the deferred gain be allocated between the partners?
2. What is the one transaction which will cause an inside-outside basis disparity, but does not allow a Code Sec. 754 election?
3. What amount is a contribution of property recorded at for tax purposes and what amount is it recorded at for book purposes?
4. How does a partner determine the holding period of his partnership interest?
5. How does a partnership determine the holding period of assets contributed by the partners?
6. If depreciable property is contributed to the partnership, what depreciation method should the partnership use to depreciate it?
7. If a partner contributes encumbered property and has net debt relief (a net decrease in her liabilities) as a result, it is treated as a deemed distribution to the partner of what?
8. Under what circumstances will a partner contributing encumbered property to a partnership have to recognize a gain?
9. Does the depreciation recapture potential of contributed property carry over to the partnership?
10. Juan contributes three parcels of property to the JKL Partnership in exchange for a 40% interest in the partnership. The properties were as follows:
FMV Basis
Property A $120,000 $70,000
Property B $180,000 $160,000
Property C $100,000 $200,000
If Property A is later sold for $140,000, how much gain will Juan recognize? If Property A is later sold for $100,000, how much gain will Juan recognize?
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