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. - $2,000, F.M.V- $10,000). Unless otherwise stated, the partnership is not a dealer in receivables or land, 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 results 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? Reg. 1.704-3 (a)(7). See chapters 6, 7, 8, and 9, infra. The basic strategy involved a transfer of a partnership interest or distribution where the partnership did not make a section 754 election to reduce the inside basis of the partnership's property under section indicates that an expection should be created for a corporation succeeding to the tax attributes of a corporate partner under section 381. H. Rep. No. 108-548, 108th Cong., 2d Sess. 283 note 312(2004) Same as (c), above, except the partnership elects to use the remedial method of allocation. The partnership is a real estate dealer and sells the land contributed by C for $17,000? Same as (e), above, except the sale is for $7,000? Would the result in any of the above transactions change if all sales had occurred six years after the property was contributed? A contributes $100,000 cash to the AB partnership and B contributes a ling with an adjusted basis of $50,000 and a fair market value of 5,000. Unless otherwise stated, apply the traditional method with ct to all contributed property. 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. - $2,000, F.M.V- $10,000). Unless otherwise stated, the partnership is not a dealer in receivables or land, 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 results 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? Reg. 1.704-3 (a)(7). See chapters 6, 7, 8, and 9, infra. The basic strategy involved a transfer of a partnership interest or distribution where the partnership did not make a section 754 election to reduce the inside basis of the partnership's property under section indicates that an expection should be created for a corporation succeeding to the tax attributes of a corporate partner under section 381. H. Rep. No. 108-548, 108th Cong., 2d Sess. 283 note 312(2004) Same as (c), above, except the partnership elects to use the remedial method of allocation. The partnership is a real estate dealer and sells the land contributed by C for $17,000? Same as (e), above, except the sale is for $7,000? Would the result in any of the above transactions change if all sales had occurred six years after the property was contributed? A contributes $100,000 cash to the AB partnership and B contributes a ling with an adjusted basis of $50,000 and a fair market value of 5,000. Unless otherwise stated, apply the traditional method with ct to all contributed property
