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Miniver Partners (Miniver), is a California General Partnership. Miniver was founded by three partners, Clem, Kay and Toby, who have the following capital and profits

Miniver Partners (Miniver), is a California General Partnership. Miniver was founded by three partners, Clem, Kay and Toby, who have the following capital and profits interests in Miniver: Clem: 40% Kay: 35% Toby: 25% Miniver manufactures general equipment for use in movie theatres, which are experiencing a resurgence in this post Covid era. Miniver was formed on January 1, 2022 through the following contributions: Clem contributed 600,000 cash, Kay contributed 525,000 cash and Toby contributed land with a basis of 295,000 but with a fair value of 375,000. I have included below an excerpt of certain financial information for Miniver for the year ended December 31, 2022: Sales income popcorn machines, theatre seats, etc. = 740,000 Cost of Goods Sold popcorn machines, theatre seats, etc. = 325,000 Advertising expenses = 48,000 Dividend income = 3,800 Wages = 55,000 Section 179 Depreciation = 63,000 Nondeductible fines = 55,000 Long term capital gain / (loss) = (35,000) Guaranteed Payment to Toby = 33,500 At 31 Dec 2022, the Miniver partnership balance sheet indicated 53,000 of nonrecourse liabilities. At 1 Jan 2022, the Miniver Partnership balance sheet indicated -0- of nonrecourse liabilities. Please provide the following with regard to Miniver: a) Clems, Kays and Tobys realized AND recognized gain/(loss) upon the contribution of assets into Miniver b) Tax basis amounts: Clems Kays and Tobys tax basis in the Miniver partnership as of 1 Jan 2022 and Minivers tax basis in its partnership assets as of 1 Jan 2022 c) The trade or business income of Miniver as well as the separately stated items for Clem, Kay and Toby for the year ended 31 Dec 2022; and d) Clems, Kays and Tobys partnership interest basis in Miniver as of 31 December 2022. e) Assume that Miniver decided to sell the land that was contributed by Toby. Assume that the sales price is 440,000 and that the sale would occur during 2023. What would be the amount of gain and how would the gain be allocated among Clem, Kay and Toby?

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