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If a partner contributes depreciable or amortizable property to the partnership, how is the basis of those properties recovered? In addition, what types of expenditures

If a partner contributes depreciable or amortizable property to the partnership, how is the basis of those properties recovered? In addition, what types of expenditures might a new partnership incur? How are those costs treated for Federal tax purposes?

In the chart below, for each expenditure listed, select the tax treatment of expenditures of a new partnership and the applicable Code section.

Type of Expenditure Contributed depreciable or amortizable property
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized; no amortization permittedDeductible currentlyCapitalized and amortized over 180 monthsPartnership steps into shoes of contributing partner
Reference
162 168(i)(7), Reg. 1.167(a)3 195 709 197Reg. 1.167-3
Type of Expenditure Acquisition of property
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currentlyCapitalized and amortized over 180 months
Reference
162 167, 168, 179 195 709 197Reg. 1.167-3
Type of Expenditure Startup expenses
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currently$5,000 expensed; remainder capitalized and amortized over 180 months
Reference
162 167, 168 195 709 197Reg. 1.167-3
Type of Expenditure Organization costs
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currently$5,000 expensed; remainder capitalized and amortized over 180 months
Reference
162 167, 168 195 709 197Reg. 1.167-3
Type of Expenditure Syndication costs
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currentlyCapitalized and amortized over 180 months
Reference
162 167, 168 195 709 197Reg. 1.167-3
Type of Expenditure Goodwill and similar intangible assets
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currentlyCapitalized and amortized over 180 months
Reference
162 167, 168 195 709 197Reg. 1.167-3
Type of Expenditure Other intangibles
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currentlyCapitalized and amortized over 180 months
Reference
162 195 709 197Reg. 1.167-3
Type of Expenditure Ordinary and necessary post-operating business expense
Treatment
Amortized over 15 yearsAmortized over useful lifeCapitalized and depreciatedCapitalized; no amortization permittedDeductible currentlyCapitalized and amortized over 180 months
Reference
162 167, 168 195 709 197Reg. 1.167-3

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