Question
Dave LaCroix recently received a 10 percent capital and profits interest in Cirque Capital LLC in exchange for consulting services he provided. If Cirque Capital
Dave LaCroix recently received a 10 percent capital and profits interest in Cirque Capital LLC in exchange for consulting services he provided. If Cirque Capital had paid an outsider to provide the advice, it would have deducted the payment as compensation expense. Cirque Capitals balance sheet on the day Dave received his capital interest appears below:
Basis | Fair Market Value | ||||
Assets: | |||||
Cash | $ | 260,000 | $ | 260,000 | |
Investments | 300,000 | 322,000 | |||
Land | 200,000 | 390,000 | |||
Totals | $ | 760,000 | $ | 972,000 | |
Liabilities and capital: | |||||
Nonrecourse Debt | $ | 180,000 | $ | 180,000 | |
Lance* | 290,000 | 396,000 | |||
Robert* | 290,000 | 396,000 | |||
Totals | $ | 760,000 | $ | 972,000 | |
*Assume that Lances basis and Roberts basis in their LLC interests equal their tax basis capital accounts plus their respective shares of nonrecourse debt. (Leave no answer blank. Enter zero if applicable.)
a. Compute and characterize any gain or loss Dave may have to recognize as a result of his admission to Cirque Capital.
b. Compute each members tax basis in his LLC interest immediately after Daves receipt of his interest.
Dave-
Lance-
Robert-
c. Prepare a balance sheet for Cirque Capital immediately after Daves admission showing the members tax capital accounts and their capital accounts stated at fair market value.
Cirque, LLC | ||
Balance Sheet | ||
Tax Basis | 704(b)/FMV | |
Assets: | ||
Cash | ||
Investments | ||
Land | ||
Totals | ||
Capital: | ||
Nonrecourse Debt | ||
Capital-Lance | ||
Capital-Robert | ||
Capital-Dave | ||
Totals |
e. Compute each members tax basis in his LLC interest immediately after Daves receipt of his interest if Dave receives only a profits interest.
Dave | Lance | Robert | |
Tax basis |
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