Question
1. James Michaels invested $25,000 for a one-third interest in the Jabo Partnership on January 1 of the current year. The partnership purchased a building
1. James Michaels invested $25,000 for a one-third interest in the Jabo Partnership on January 1 of the current year. The partnership purchased a building site on February 5 at a cost of $200,000, paying $50,000 as a down payment and obtaining a mortgage of $150,000 at 12 percent annual interest for only three years, then full payment of principal. Because of an unexpected rezoning of the property, it substantially increased in value. Jabo Partnership broke exactly even for the current year since their income was exactly the same as their expenses. On December 31 James sold his one-third interest to Joe Hammer, receiving $62,500 in cash. What was Jamess basis for his interest in the partnership immediately prior to the sale? What was the sales price of the interest? What is the character of Jamess gain upon the sale of his interest?
2. Assume the same facts as in problem 33 except that Neds basis in the building is only $20,000. Determine each partners adjusted basis in his partnership interest. Does either partner recognize any gain on the transfer to the partnership? What is JNs basis in the assets?
3. Marvin Bridges is a 25 percent partner in the Munson partnership. On November 23, 2017, Marvin contributes property with an adjusted basis of $75,000 and a fair market value of $250,000 to the Munson partnership. On March 15, 2018, Marvin receives a $187,500 cash distribution from the partnership. a) Why would the IRS seek to classify the transactions as a disguised sale? b) . Assume that the IRS is successful in classifying the transactions as a disguised sale. Outline the income tax consequences to Marvin
4. On September 1, 2013, Leonard contributed land held for investment with a fair market value of $200,000 and an adjusted basis to him of $120,000 for a 20 percent interest in the income and capital of Office Complex Partnership. The land was intended for use as a building site for the partnership. The partnership opted to rent facilities and on September 2, 2018, sold the contributed land for $500,000. Assuming the partnership agreement was silent with respect to this particular asset, how much gain must Leonard report for this partnership sale?
5. On January 17 of the current year, the Bamber Partnership was formed by Bob Miller, Carl Penn, and Don Allen. Each partner has an equal interest in the capital and profits of the partnership. The Bamber partnership will report on the basis of a calendar year. The following contributions were made when the partnership was formed.
Parter | Property | Basis to Partner | FMV |
Bob | Cash | 15,000 | 15,000 |
Carl | Inventory | 9,000 | 15,000 |
Don | Captial Asset | 35,000 | 15,000 |
Both the inventory and capital asset are inventory to the Bamber partnership. On May 22 the partnership sells the inventory for $27,000. On July 19 the partnership sells the capital asset which Don contributed for $9,000. The partnership agreement is silent regarding the property contributed by the partners. Without regard to the sale of the contributed properties, the Bamber partnership reports $60,000 of ordinary income for its current tax year. As a result of partnership transactions, what does each partner report on his individual tax return for the current year?
6. Because it was anticipated that Bob Short would devote more time to the partnership than would his equal partner Jack Long, it was agreed that Bob would receive a salary of $12,000 per year. Bob and Jack agreed to divide the remaining partnership income equally. For the current year, prior to consideration of Bobs salary, the partnership income was composed of $6,000 long-term capital gain, $2,000 tax-exempt interest, and $8,000 loss from operations. Determine the amount and character of income (loss) reportable by Bob and Jack for the current year.
7. In 2018 the XYZ Partnership incurred the following expenses:
Expenses of selling partnership interests | $10,000 |
Attorney's fees for drafting partnership agreement | 30,000 |
Exoenses of transferring title of property to partnersip | 8,000 |
Accounting fees to organize partnership | 22,000 |
If XYZ began business on August 1, 2018, how much in total of these expenses could XYZ deduct (including amortization)?
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