is a one-third general partner in the DEF partnership. Both D and the partnership are cash method, calendar year taxpayers. D dies at a time when the partnership has earned $15,000 for the current year, and his share of the untaxed and undistributed partnership income for the year is $5,000. Under all of the sale or liquidation agreements described below, D is to be paid $30,000 for his interest, which includes his share of income. Immediately prior to Ds death, the DEF partnership has the following balance sheet:

Assets Partners Capital

A.B. F.M.V. A.B. F.M.V.

Cash $9,000 $9,000 D $3,000 $30,000

Cash (not yet in D

E, And Fs income) 15,000 15,000 E 3,000 30,000

Receivables for 0 45,000 F 3,000 30,000

Services Depreciable

Section 1245 property 0 3,000

Goodwill 0 18,000

$24,000 $90,000 $9,000 $90,000

Assume, alternatively, that Ds interest: (1) passes to his estate; (2) is subject to a buy-out agreement at his death; (3) is liquidated by the partnership (which is a services partnership); or (4) is liquidated by the partnership in which capital is a material income-producing factor. Under each alternative, consider the following question:

(a) Does the partnerships taxable year close as to Ds estate?

(b) What is the amount included in Ds gross estate?

(c) To what extent does the interest included in Ds gross estate constitute income in respect of a decedent?

(d) What outside basis does Ds estate take in the partnership interest immediately following Ds death