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Marco, Jaclyn, and Carrie formed Daxing partnership (a calendar year-end entity) by contributing cash 10 years ago. Each partner owns an equal interest in the

Marco, Jaclyn, and Carrie formed Daxing partnership (a calendar year-end entity) by contributing cash 10 years ago. Each partner owns an equal interest in the partnership. Marco, Jaclyn, and Carrie each have an outside basis in his/her partnership interest of $104,000. On January 1 of the current year, Marco sells his partnership interest to Ryan for a cash payment of $137,000. The partnership has the following assets and no liabilities as of the sale date:

Tax Basis Fair Market Value

Cash $ 18,000 $ 18,000

Accounts receivable -0- 11,000

Inventory 69,000 81,000

Equipment 180,000 225,000

Stock investment 45,000 75,000

Totals $ 312,000 $ 410,000

The equipment was purchased for $240,000 and the partnership has taken $60,000 of depreciation. The stock was purchased 7 years ago. What is the total amount of the hot assets (751(a)) for this sale, i.e., the amount that would require gain or loss to be recharacterized as ordinary income?

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