Question
A and B are equal partners in a personal services partnership. Each partner acquired her partnership interest for cash several years ago. None of the
A and B are equal partners in a personal services partnership. Each partner acquired her partnership interest for cash several years ago. None of the partnerships assets is Section 704(c) property. The partnership has the following balance sheet:
Assets Liabilities and Partners Capital
A.B. F.M.V. A.B.* F.M.V.
Cash $13,000 $12,000 Liabilities: $2,000
Capital Assets: Capital:
Collectibles 1,000 3,000 A $10,000 15,000
Other 6,000 2,000 B 10,000 15,000
Subtotal 7,000 5,000
Receivables 0 14,000
Total $20,000 $32,000 $20,000 $32,000
Consider the tax consequences to B on her sale in each of the following alternative situations:
- B sells her interest for $15,000 cash
- B sells her interest for $16,000 cash and under the partnership agreement all gain from the sale of the collectibles is allocated to B
- Same as (a), above, except that the collectibles have a basis of $3,000 and a fair market value of $1,000, and the other capital asset has a basis of $4,000 and a fair market value of $4,000.
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