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ABC Partnership is owned 30% by Sara, 30% by Sully, and 40% by Tanner. Barrington, Inc. is owned 50% by ABC Partnership, 10% by Roy,

image text in transcribedimage text in transcribed ABC Partnership is owned 30% by Sara, 30% by Sully, and 40% by Tanner. Barrington, Inc. is owned 50% by ABC Partnership, 10% by Roy, 10% by Tanner, and 30% by Sara. Roy and Tanner are brothers. All other individuals are unrelated. During the current year, Roy sold a piece of land to Barrington, Inc., for $80,000. Roy originally purchasec the land as an investment a few years ago for $97,500. Requirement a. How much of the loss may Roy recognize? Begin by determining Roy's constructive ownership in Barrington, Inc. (Enter percentages as whole numbers.) How much of the loss may Roy recognize? (Assume that Roy has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) The realized loss is . Under the related party rules (Sec. 267), since Roy of Barrington Inc. he allowed to recognize this loss on the sale of land to Barrington Inc. Requirement b. Now assume all the same facts except that the sale occurred between Tanner and Barrington, Inc. How much of the loss may Tanner recognize? Begin by determining Tanner's constructive ownership in Barrington, Inc. (Enter percentages as whole numbers.) How much of the loss may Tanner recognize? (Assume that Tanner has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) Under the related party rules (Sec. 267), since Tanner constructively of Barrington Corporation, he to recognize this loss on the sale of land to Barrington Corporation. Requirement c. Now assume the same facts as in b except that Barrington, Inc., is owned 70% by Sara and 30% by Roy. Tanner sells the land to Barrington, Inc. How much of the loss may Tanner recognize? (Assume that Tanner has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) In this case, Tanner is treated Thus, Tanner to recognize this loss on the sale of land to Barrington, Inc

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