Question
McKenzie, Brackman & Chaney is an equal general partnership engaged in legal practice (i.e., it is a service partnership). McKenzie is planning to retire. On
McKenzie, Brackman & Chaney is an equal general partnership engaged in legal practice (i.e., it is a service partnership). McKenzie is planning to retire. On January 1 of Year 1, McKenzies outside basis is $100. The partnership has made a 754 election. On this date, the partnerships balance sheet is as follows (expanded to include goodwill and fair market values)
Assets Liabilities & Capital
AB/Bk FMV Mortgage $150
Cash $120 $120
Accts Rec. 0 75
Building 90 255
Land 90 300
Goodwill 0 150
$300 $900
Capital Accounts Tax/Bk FMV
McKenzie $50 $250
Brackman 50 250
Chaney 50 250
$150 $750
Assume that no principal payments are due on the mortgage until Year 5. What are the tax consequences to McKenzie if, in the alternative:
(a) Brackman and Chaney purchase McKenzies partnership interest, each paying $125 cash.
(b) The partnership makes a lump sum payment to McKenzie in the amount of $250 in complete liquidation of McKenzies interest in the partnership, and the agreement makes no reference to partnership goodwill?
(c) The partnership makes a lump sum payment to McKenzie in the amount of $250 in complete liquidation of McKenzies interest in the partnership. Under the partnership agreement, $50 of the payment is specifically allocated to McKenzies share of the partnerships goodwill.
(d) How would your answer to part (b) change if the partnership agrees to pay McKenzie the $250 over time: $50 in Year 1, $100 in Year 2 and a final $100 in Year 3? McKenzie agrees to remain personally liable on mortgage until he receives her last payment.
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started