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100 North Avenue A LP is a limited partnership formed for the sole purpose of developing a small commercial building at that address. Its initial
100 North Avenue A LP is a limited partnership formed for the sole purpose of developing a small commercial building at that address. Its initial total capital is $1 million. JP, a local contractor, is offered a 10% capital interest in the partnership in exchange for his services as construction manager of the project. Assume that the partnership's proposal to JP includes two- year cliff vesting, meaning that JP will forfeit his interest unless he works for the partnership for at least two years. Also assume for purposes of this question that JP timely makes a sec. 83(b) election. On the vesting date, the JP's 10% interest is worth $1,250,000. What is the JP's compensation income in the year of the grant and in the year of vesting? O Grant, $100,000; vesting $0 O Grant, $0; vesting $0 O Grant, $100,000; vesting, $1,150,000 Grant, $0; vesting, $1,250,000
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