Question
John has a 60% capital and profits interest in the JAS Partnership with a basis of $333,600, which includes his share of liabilities, when he
John has a 60% capital and profits interest in the JAS Partnership with a basis of $333,600, which includes his share of liabilities, when he decides to retire. Andrew and Stephen want to continue the partnership's business. On the date John retires (assume 2022), the partnership's balance sheet is as follows:
a. | What are the tax implications forJohn,Andrew,Stephen, and the JAS Partnership if Andrew and Stephen each purchase one-half of John's partnership interest for a cash price of $186,000 each? Include in your answer the amount and character of the recognized gain or loss, basis of the partnership assets, and any other relevant tax implications. |
b. | What are the tax implications forJohn,Andrew,Stephen, and the JAS Partnership if the partnership pays John a liquidating distribution equal to 60% of each partnership asset other than cash plus $24,000 of cash? Assume the assets are easily divisible. |
Partnership's Basis | FMV | ||
Assets: |
|
| |
Cash | $160,000 | $160,000 | |
Receivables | 100,000 | 100,000 | |
Building | 200,000 | 300,000 | |
Land | 96,000 | 180,000 | |
Total | $556,000 | $740,000 | |
Liabilities and capital: |
|
| |
Liabilities | $120,000 | $120,000 | |
Capital - John | 261,600 | 372,000 | |
- Andrew | 87,200 | 124,000 | |
- Stephen | 87,200 | 124,000 | |
Total | $556,000 | $740,000 | |
The partnership has claimed $60,000 of straight-line depreciation on the | |||
building. |
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