Question
Daniel and Emma form HP Enterprises, LLC a partnership designed to market and sell Harry Potter merchandise. In exchange for equal partnership interests (capital, profits
Daniel and Emma form HP Enterprises, LLC a partnership designed to market and sell Harry Potter merchandise. In exchange for equal partnership interests (capital, profits and losses) Daniel and Emma contribute the following:
Daniel: AB FMV
Cash $80,000 $80,000
Property $70,000 $100,000
Debt associated with the property $30,000 $30,000
Emma contributed cash of $150,000.
1. In exchange for handling the day-to-day management of the partnership, Daniel received payments of $75,000.
2. HP borrowed $100,000 for additional working capital.
3. HP had net income of $500,000 before guaranteed payments.
4. This $500,000 included $50,000 of capital gains from the sale of the property contributed by Daniel. Note that the debt associated with the property was paid off at the time of the sale.
5. Daniel and Emma each received distributions of $80,000 over the course of the year
How much income/loss will be allocated to Daniel?
What will Daniel's ending outside basis be at the end or the year?
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