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g-1. If Reed sells his interest in Slicenhook to Indie Ruff, what are the amount and character of his recognized gain or loss? g-2. What

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  1. g-1. If Reed sells his interest in Slicenhook to Indie Ruff, what are the amount and character of his recognized gain or loss?

  2. g-2. What is Indies basis in the partnership interest?

  3. h-1. If Reed sells his interest in Slicenhook to Indie Ruff, what is Indie's inside basis in Slicenhook?

  4. h-2. What effect would a 754 election have on Indies inside basis?

  5. i-1. If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reeds partnership interest, what are the amount and character of Reeds recognized gain or loss?

  6. i-2. If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reeds partnership interest, what is Reeds basis in the distributed assets?

  7. j-1. If Reed sells his interest, what is his after-tax cash? Assume his ordinary marginal tax rate is 35 percent and his capital gains tax rate is 15 percent.

  8. j-2. If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reed's partnership interest and Reed were to immediately sell the distributed assets, what is his after-tax cash? Assume his marginal tax rate is 35 percent and his capital gains rate is 15 percent.

Carrle D'Lake, Reed A. Green, and Doug A. Divot share a passion for golf and decide to go Into the golf club manufacturing business together. On January 2, 2021, D'Lake, Green, and Divot form the Slicenhook Partnership, a general partnership. Slicenhook's main product will be a perimeter-welghted tltanium driver with a patented graphite shaft. All three partners plan to actively participate in the business. The partners contribute the following property to form Slicenhook: Carrle had recently acquired the land with the Idea that she would contribute it to the newly formed partnership. The partners agree to share in profits and losses equally. Slicenhook elects a calendar year-end and the accrual method of accounting. In addition, Slicenhook recelved a $1,500,000 recourse loan from Big Bank at the time the contributions were made. Slicenhook uses the proceeds from the Ioan and the cash contrlbutions to bulld a state-of-the-art manufacturing facility ($1,200,000), purchase equipment ($600,000), and produce Inventory ($400,000). With the remaining cash, Slicenhook Invests $45,000 in the stock of a privately owned graphite research company and retains $55,000 as working cash. Slicenhook operates on a just-In-time Inventory system so It sells all inventory and collects all sales Immediately. That means that at the end of the year, Slicenhook does not carry any inventory or accounts recelvable balances. During 2021 , Slicenhook has the following operating results: The partnership is very successful In Its first year. The success allows Slicenhook to use excess cash from operations to purchase $15,000 of tax-exempt bonds (you can see the Interest Income already reflected in the operating results). The partnership also makes a principal payment on its loan from Big Bank in the amount of $300,000 and a distribution of $100,000 to each of the partners on December 31,2021 . The partnership continues its success in 2022 with the following operating results: The operating expenses Include a $1,800 trucking fine that one of Its drivers Incurred for reckless driving and speeding and meals expense of $6,000 (the meals were not provided by a restaurant). By the end of 2022, Reed has had a falling out with Carrle and Doug and has decided to leave the partnership. He has located a potentlal buyer for his partnership interest, Indle Ruff. Indie has agreed to purchase Reed's Interest In Slicenhook for $730,000 In cash and the assumption of Reed's share of Slicenhook's debt. Carrle and Doug, however, are not certain that admitting Indle to the partnership is such a good idea. They want to consider having Slicenhook liquidate Reed's Interest on January 1, 2023. As of January 1, 2023, Slicenhook has the following assets: Carrle and Doug propose that Slicenhook distribute the following to Reed In complete liquidation of his partnership Interest

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