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On January 1 , Year 1 , C and D formed a general partnership. The partnership agreement complies with the Basic Test. The partnership uses
On January Year C and D formed a general partnership. The partnership agreement complies with the Basic Test. The partnership uses the Remedial Allocation Method.
Book Allocations. The agreement allocates book items between the partners as follows:
For Year through Year :
a to C and to D provided, however, that nonrecourse deductions are allocated equally between the two partners :; and
For Year and thereafter, to C and to D
You are to assume that these allocations meet the substantiality requirement.
Tier NonRecourse Liability Allocation. The partnership has elected to have all nonrecourse liabilities allocated under Tier to be allocated in accordance with the partners respective shares of profits. You are to assume that this means: in Years through Year the Tier liability allocations are to C and to D; and in Year and thereafter, the Tier liability allocations are to C and to D And you are to assume that this choice is allowed.
The problem set continues on the next page.
Contributions. The contributions to the partnership on formation were:
C contributed equipment, on which, at the time of contribution, C had years of straightline depreciation left. The fair market value of this contributed equipment, at the time of contribution, was $ and Cs basis in the equipment was $ The contributed equipment was subject to a nonrecourse liability of $
D contributed $ in cash.
During each of Year and Year the partnership paid interest on the loan, but principal payments were not made. So the principal amount of the liability remained the same at all times. In each of those years, the partnerships net income before depreciation was zero. So on a tax basis, in each of Year and Year the partnership had a net loss equal to the depreciation on the contributed equipment.
The partnership did not make any distributions in either Year or Year
In answer to this problem, answer the questions posed below by filling in the indicated blanks:
On formation, the partners tax capital accounts were:
Cs tax capital account was: $
Ds tax capital account was: $
On Year the partners tax capital accounts were:
Cs tax capital account was: $
Ds tax capital account was: $
On Year the partners outside bases were:
Cs outside basis was: $
Ds outside basis was: $
On Year the partners tax capital accounts were:
Cs tax capital account was: $
Ds tax capital account was: $
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