Question
A, B and C form an equal partnership. A contributes accounts receivable for services rendered (A.B.-- $0, F.M.V.-- $10,000); B, a real estate dealer, contributes
A, B and C form an equal partnership. A contributes accounts receivable for services rendered (A.B.-- $0, F.M.V.-- $10,000); B, a real estate dealer, contributes lots held primarily for sale (A.B. -- $5,000, F.M.V. -- $10,000); and C, an investor, contributes land (A.B. -- $20,000, F.M.V. -- $10,000). Unless otherwise stated, the partnership is not a dealer in receivables or lad, all contributed assets have been held long-term by the partners prior to contribution, and the traditional method of allocation is applied with respect to all contributed property. What tax result in the following alternative transactions:
(a) The partnership sells the receivables contributed by A for $10,000?
(b) The partnership sells the lots contributed by B for $10,600?
(c) The partnership sells the lots contributed by B for $9,100?
(d) Same as (c), above, except the partnership elects to use the remedial method of allocation.
(e) The partnership is a real estate dealer and sells the land contributed by C for $17,000?
(f) Same as (e), above, except the sale is for $7,000?
(g) Would the result in any of the above transactions change if all sales have occurred 6 years after the property was contributed?
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