Question
Economic Risk of Loss: Allocating Recourse Liabilities of a General Partnership A and B organized a general partnership in the current year to acquire and
Economic Risk of Loss: Allocating Recourse Liabilities of a General Partnership A and B organized a general partnership in the current year to acquire and develop a tract of land. Each contributed $20 to the partnership for a 50 percent interest in capital, profits and losses. The partnership purchased the land from a third party for $200. It paid the price with the funds contributed by the partners and a mortgage loan of $160. Assume under local law that A and B are each jointly and severally liable to repay 26 the mortgage, including interest, if the partnership cannot pay it. The partnership agreement contains the appropriate capital account deficit restoration provisions.
(a) The partnership engaged in no transactions during the year other than the purchase of the land. What is the basis of each partner's interest at the end of current year?
(b) Would it make any difference in (a) if the partnership had borrowed the $160 from A or had purchased the property from A on a deferred payment basis, in each case giving A its $160 recourse obligation?
(c) Same as (a), except that A contributed $40 and B contributed no initial capital, but they still agree to share profits and losses equally.
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