Question
A and B are equal partners that previously formed the AB Partnership whose only asset is Building #1 that has a FMV of $800,000 and
A and B are equal partners that previously formed the AB Partnership whose only asset is Building #1 that has a FMV of $800,000 and an adjusted basis of $300,000. On December 31, 2021, C joins the partnership obtaining a 3rd ownership interest in exchange for contributing Building #2. Building #2 has a FMV of $700,000 and an adjusted basis of $150,000 and is subject to a recourse liability of $300,000 (that the partnership assumes). At the time of Cs entry into the partnership the partnership revalues its assets under Reg. 1.704-1(b)(2)(iv)(f): A) How is the $300,000 liability allocated? B) How would this $300,000 liability be allocated if the liability were instead non-recourse and secured by Building #2 and the partners agree to use the traditional method to allocate IRC 704(c) gain?
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