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Following a nice run-up in the markets, A, B and C each contributes a diversified portfolio (Portfolios A, B and C, respectively) of publicly traded
Following a nice run-up in the markets, A, B and C each contributes a diversified portfolio (Portfolios A, B and C, respectively) of publicly traded stocks to form the Broad Street Investment Partnership. On contribution, each portfolio has a value of $2 million, and their adjusted bases are: Portfolio A, $1 million; Portfolio B, $500,000; and Portfolio C, $1.5 million. A, B and C are equal, one-third partners in Broad Street, except that under the partnership agreement each partner retains the first $250,000 of book gain or loss from the sale of the stocks in the portfolio contributed by that partner. The partnership maintains proper capital accounts, which govern the distribution of liquidation proceeds, and has elected the remedial allocation method. What goes up must come down. If Broad Street now sells Portfolio B for $1 million, how much book and tax gain or loss will be allocated to B, including remedial allocations, if any?
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