Question
Ingrid, Bastian, and Tina are general partners of IBT Partnership. They share profits & losses 30/60/10%. IBT's balance sheet is as follows: Assets FMV Adjusted
Ingrid, Bastian, and Tina are general partners of IBT Partnership. They share profits & losses 30/60/10%. IBT's balance sheet is as follows:
Assets
FMV
Adjusted basis
Cash
$100,00 $100,000
Inventory
$100,000 $70,000
Marketable securities
$140,000 $95,000
Building (net of depreciation)
$100,000 $90,000
Land (investment asset)
$160,000 $120,000
Total assets
$600,000 $475,000
Liability & capital accounts
Non-recourse debt
$400,000 $400,000
Ingrid's capital account
$70,000 $25,000
Bastian's capital account
$100,000 $80,000
Tina's capital account
$30,000 $(30,000)
Total liabilities & capital accounts
$600,000 $475,000
Requirements:
For each of the following independent situations determine:
- Each partner's pre- and post-transaction basis in the partnership.
- The partnership's basis in the assets on its balance sheet.
- Amount and character of gain or loss recognized, if any.
IBT has a section 754 election in effect.
Situation 1: Tina sells one-half of her interest in IBT Partnership to Toni for $30,000 cash.
Situation 2: In a complete liquidation, Tina receives $20,000 of the inventory from the partnership.
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