Question
In which of the following independent situations would the transaction most likely be characterized as a disguised sale? a. Partner George contributes appreciated property to
In which of the following independent situations would the transaction most likely be characterized as a disguised sale?
a. | Partner George contributes appreciated property to the GM Partnership, and three years later GM distributes $100,000 proportionately to the partners. | |
b. | Brianna contributes property with a basis of $20,000 and a fair market value of $50,000 to the BGB Partnership in exchange for a 20% interest therein. The partnership agrees to distribute $20,000 to Brianna in fifteen months, if partnership cash flows from operations exceed $100,000 at that time. The partnership does not expect to produce operating cash flows of over $100,000 for at least five years. | |
c. | Luis contributes appreciated property to the BLP Partnership. Thirty months later, he receives a distribution from the partnership of $15,000 cash. None of the other partners received a distribution. There was no agreement that BLP would make the distribution, and Luis would have made the contribution whether or not the partnership made the distribution. | |
d. | None of the above transactions will be treated as a disguised sale. | |
e. |
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