Question
Minnie and Paul form a partnership and agree to report equal distributive shares of the partnership's income, gains, losses, and deductions. Assuming that capital accounts
(a) Minnie contributes $500 of cash and a building with a tax basis of $100 and a fair market value of $200 that is encumbered by a $150 mortgage.
(b) Paul contributes a $500 personal promissory note and a truck with a $300 basis and a $50 fair market value. Would the answer change if the promissory note was owed by a third party?
(c) In its first year, the partnership has the following items: $400 of operating income, $100 of tax-exempt bond interest, a $40 capital loss (not deductible by Minnie under§ 1211, fully deductible by Paul), a $60 loss (suspended under § 465), and $20 of nondeductible, noncapitalizable expenses.
(d) The partnership borrows $1,000. Six months later, the partnership pays off the liability.
(e)The partnership borrows $1,000. Six months later, Minnie assumes the liability. The bank is fully aware of the assumption and can proceed directly against Minnie. One year later, the partnership pays off the liability
(f) The partnership distributes $100 each to Minnie and Paul.
(g) The partnership purchases (as an investment) a small collection of antique jewelry for $500. After it appreciates to $1,000, the partnership distributes it to Minnie.
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