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Lemon, Lime, and Orange, three cash method, calendar year individuals, form Starburst General Partnership to create fruit candies. Before forming this partnership, they each
Lemon, Lime, and Orange, three cash method, calendar year individuals, form Starburst General Partnership to create fruit candies. Before forming this partnership, they each had their own sole proprietorship. The partners contribute the following property (in each case worth $1,600 net of liabilities) in exchange for equal 1/3 interests in the partnership's capital, profits and losses (see the table below of property contributed by each partner). The partnership assumes all liabilities encumbering the contributed assets. Assume that the partners are responsible for an equal share of the partnership's liabilities. What is the most that any specific partner recognizes on these transactions? Lemon contributes land with a fair market value of $3,440, which is encumbered by a recourse mortgage of $2,160. Lemon has held the land for several years as an investment, and his basis in the land is $800. Lemon also contributes $320 in cash. Lime contributes a building, a 1231 asset, with a value of $2,080 in which Lime has an adjusted basis of $1,040. The building was purchased several years ago by Lime and is subject to a recourse mortgage $480. Orange contributes zero basis accounts receivable from his business worth $2,800 and assigns his accounts payable of $1,200 to the partnership.
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