Question
A, B and C form a general partnership. A contributes Land, a capital asset A acquired several years ago, worth $160 in which A has
A, B and C form a general partnership. A contributes Land, a capital asset A acquired several years ago, worth $160 in which A has a tax basis of $40. The land is subject to a mortgage of $60. Liabilities of the partnership are allocated to the partners on a pro rata basis (i.e., 1/3 to each partner). However, the partnership agreement does not include a DRO or a QIO. Accordingly, A has no obligation to restore a deficit to their capital account in determining whether partnership allocations comply with Sec. 704(b) of the IRC. Immediately after the partnership's formation, what is A' tax capital account? |
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