Lonnie Davis has been a general partner in the Highland Partnership for many years and is also a sole proprietor in a separate business. To spend more time focusing on his sole proprietorship, he plans to leave Highland and will receive a liquidating distribution of $72,000 in cash and land with a fair market value of $135,500 (tax basis of $173,000). Immediately before the distribution, Lonnies basis in his partnership interest is $448,000, which includes his $79,500 share of partnership debt. The Highland Partnership does not hold any hot assets.

a. What is the amount and character of any gain or loss to Lonnie?

b. What is Lonnies basis in the land? c. What is the amount and character of Lonnies gain or loss if he holds the land for 13 months as investment property and then sells it for $163,000? d. Assume there are no gains from the sale of other Section 1231 in the same tax year. What is the amount and character of Lonnies gain or loss if he places the land into service in his sole proprietorship and then sells it 13 months later for $163,000?