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I need to answer question f of e and f. During the current tax year, Dave and Stu formed the DS LLC with Dave contributing
I need to answer question f of e and f.
During the current tax year, Dave and Stu formed the DS LLC with Dave contributing land with a basis of $360,000 and a fair market value of $600,000 at the contribution date. At the end of the year, the LLC distributes $300,000 of cash to Dave. The LLC made no distributions to Stu. Assume that there were no other income or loss transactions for the vear that would affect Dave's basis in his LLC interest If an amount is zero, enter"0". a. Under general tax rules, the $300,000 would be treated as a distribution b. Under general tax rules, the income or gain that Dave recognizes as a result of the payment is 0 . Y CHOW A disguised sale may occur when a partner/member contributes appreciated property to a partnership/LLC and soon thereafter receive distribution from the partnership/LLC. C. Under general tax rules, what basis would the LLC take in the land Dave contributed? 360,000 Feedback Check My Work Correct d. The IRS might assert that the contribution and distribution transactions were, in effect A disguised wale a 120,000 and the basis the LLC would take in the land e. and 1. Under this treatment, Dave would recognize again of $ contributed by Dave would be s 240,000 x Partially correct Q. How can the transaction be restructured to minimize risk of RS recharacterization Select "Yes" or "Not whichever is applicabile Dave were subject to "entrepreneurial risk with respect to the distribution, the risk of recharacterization would be minimized. If there were an extended amount of time between the date of the formation and the distribution, the Yes risk of recharacterization would be minimized. There is no way to structure this particular transaction to minime the risk of recharacterizationStep by Step Solution
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