Kyle, Kenny, Stan, and Eric own equal interests in the capital and profits of an LLC that is taxed as a partnership. The LLC is a calendar-year taxpayer. For each of the following scenarios, determine (i) whether or not the LLC terminates and (ii) the tax consequences to the members:

a. Kyle, Kenny, and Stan simultaneously sell their entire interests in the LLC to Eric.

b. Kyle, Kenny, Stan and Eric simultaneously sell their entire interests in the LLC to Mr. Garrison, and unrelated third party.

c. On December 1, the LLC sells all its assets in exchange for a note of the purchaser. After December 1, the LLC merely holds the note and collects interest until March 31 of the following year, at which time the note is paid off and the LLC distributes the proceeds to the members in liquidation of the partnership.

d. Kyle, Kenny, and Stan form a new LLC. The new LLC purchases all of the assets of the old LLC, which liquidates by distributing the proceeds of the sale to the members.

e. Kyle and Kenny sell their entire interests to Stan and Eric, respectively, on the same day. Would your answer be different if Kyle sells his interest six months after Kenny sells his interest? One year and six months after Kenny sells his interest?

f. Kyle sells his interest to Kenny, and, six months later, Kenny sells Kyles interest to Stan. Would your answer be different if Kenny sells Kyles interest to Mr. Garrison?

g. Kyle and Kenny each sell their entire interest in the LLCs capital but only half of their respective interests in the partnerships profits.

h. The partnership completely liquidates Kyles and Kennys interests on the same day.

i. Kyle and Kenny contribute their partnership interests to a corporation in exchange for stock of the corporation in a transaction governed by IRS 351.

j. Kyle and Kenny transfer their partnership interests on the same day to Mr. Garrison as a gift.

k. Kyle and Kenny each sell all but a de minimis amount of their LLC interests to Stan and Eric. A year and a day later, they sell the remaining portions to Stan and Eric.

l. The LLC converts to a general partnership.