A. Contributions of Non-Depreciable Property

On January 1 of the current year A and B form a partnership to invest in property. A contributes investment land that she acquired two years ago, and that has a fair market value of $100. B contributes $100 in cash. Each partner receives a 50% interest in the partnership's capital, profits and losses.

1. Pre-Contribution Gain. For purposes of Problem 1, assume that As basis in the land at the time she contributed it to the partnership is $50

(a) Under the "traditional method" of accounting for 704(c) gain, how will the partnership allocate its gain or loss for book and tax purposes if the partnership sells the land for:

i. $100

ii. $150

iii. $ 70

iv. $ 30

(b) Assume the partnership invests B's cash in stock that appreciates and the partnership sells the stock at a tax and book gain of $30 in the same taxable year in which it sells the land. Would your answer to (a)(iii) above differ if the partnership used the "traditional method with curative allocations?"

(c) What if, in (b), the partnership does not sell the stock and, in fact, has no items of income, gain, loss or deduction in the year that the land is sold other than from the sale of the land: would your answer to (a)(iii) above differ if the partnership used the "traditional method with curative allocations?"

(d) How would your answer to (a)(iii) differ if the partnership used the "remedial allocation method"?

2. Pre-Contribution Loss. For purposes of this Problem 2, assume that the land has a basis in As hands at the time of contribution of $140 and its fair market value is $100. Under the traditional method, how will the partnership allocate its gain or loss for book and tax purposes if the partnership sells the land for:

(a) $70