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a sale d)(I). As with payments for 130 Ol pPuperty, Section 707(a)(2)(A) requires capitalization on item that the partners were seeking to immediately expense through

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a sale d)(I). As with payments for 130 Ol pPuperty, Section 707(a)(2)(A) requires capitalization on item that the partners were seeking to immediately expense through the ruse of an allocation of income. PROBLEMS 1. Partnership is owned Corporation, quences to the parties involved in the following sales? 25% each by A, his wife, his wife's father and X in which A is a 50% shareholder. What are the tax conse- (a) During the year the partnership sells A some land in which it has a basis of $50,000 for its fair market value of $40,000. In the succeeding year, A sells the land to B for $45,000. (b) Same as (a), above, except that the first sale is to a second partnership also owned by the same parties except that an unrelat- ed party owns a 25% interest and X Corporation owns no interest in the second partnership. The second partnership then resells the land to B for $45,000. (c) A sells depreciable equipment in which he has an adjusted basis of $20,000 to the partnership for $30,000. d) A's wife sells residential rental property held by her as a capital asset to the partnership for $120,000. She had a $100,000 basis in the property. The partnership is in the housing rental business. e) Same as (d), above, except that the partnership is in the real estate sales business

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