Code: IRC 8 706 Regulations: Treas. Reg. S 1.706-1 QUESTIONS Alvin, Dave, and Dave's wife, Laurie, are one-third partners in a calendar-year, cash-method partnership that buys and sells antique furniture and glassware. Alvin, Dave's father, has operated the business for forty years. Dave and Laurie have spent twenty-five years learning all aspects of the business. Dave's and Laurie's son, Jason, who just turned 22, would like to become a partner; Jason recently graduated from college and has worked in the business part-time for the last five years. Alvin is heading toward retirement and plans to sell all or part of his interest to 1. Jason on July 1. a. On July 1, Alvin sells his entire one-third interest to Jason. Assuming the partnership earns $300,000 for the taxable year, determine each partner's distributive share of the partnership's income for the year of the sale. Would it make any difference if the partnership liquidated Alvin's interest on July 1 and admitted Jason to the partnership (for an appropriate capital contribution) as a one-third partner on July 1? 2. Assume the same facts as in Question la except that, in the year of sale, the partnership incurs $90,000 of deductible interest and taxes attributable to the entire year. a. On July 1, right before Alvin sells his entire interest to Jason, the partnership pays both expenses, closes its books, and allocates Alvin a $30,000 distributive share of the expenses. Is this allocation valid? Suppose the partnership pays both expenses on December 31 and allocates a $30,000 distributive share to Jason. b. Suppose Alvin sells only one half of his partnership interest to Jason on July 1. Assume the same facts as in Question 2a except that the $90,000 of interest and taxes are expenses past due from the year before the sale, and the partnership pays them on January 1 of the year after the sale. How are the expenses C. allocated