Question
Frank, Greta, and Helen each have a one-third interest in the FGH Partnership. On December 31, 2018, the partnership reported the following balance sheet: Partnerships
Frank, Greta, and Helen each have a one-third interest in the FGH Partnership. On December 31, 2018, the partnership reported the following balance sheet:
| Partnerships Basis | FMV |
Assets |
|
|
Cash | $120,000 | $120,000 |
Assets 1 | 262,380 | 360,000 |
Assets 2 | 115,200 | 90,000 |
Total | $497,580 | $570,000 |
Partners Capital: |
|
|
Frank | $165, 860 | $190,000 |
Greta | $165, 860 | $190,000 |
Helen | $165, 860 | $190,000 |
Total | $497,580 | $570,000 |
The partnership placed Asset 1 (seven-year property) in service in 2016 and Asset 2 (five-year property) in service in 2017. The partnership did not elect Sec. 179 expensing and elected out of bonus depreciation in both years. Accordingly, it computed the asset adjusted bases at December 31, 2018 as follows:
|
| Asset 1 |
| Asset 2 |
Cost |
|
$600,000 |
|
$240,000 |
Depreciation |
|
|
|
|
2016 | $85,740 |
|
|
|
2017 |
146,940 |
|
$48,000 |
|
2018 |
104,940 |
(337,620) |
76,800 |
(124,800) |
Adjusted basis |
|
$262,380 |
|
$115,200 |
At the end of business on December 31, 2018, Helen sold her partnership interest to Hank for $190,000. At the time of sale, the partnership had a Sec. 754 optional basis election in effect but has not elected to use the remedial method for allocating partnership items. Required: The partners have asked you to determine (1) the amount and character of Helen gain or loss; (2) Hanks optional basis adjustment and its allocation to Asset 1 and Asset 2; and (3) the amount of depreciation allocated to Hank in 2019, including the effects of the optional basis adjustment. At a minimum, you should consult the following resources: IRC Secs. 743 and 751 Reg. Sec. 1.743-1(j)
Reg. Sec. 1.755-1
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