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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 1, Year 1, 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 1 through Year 7:
a.25% to C and 75% to D, provided, however, that non-recourse deductions are allocated equally between the two partners (50:50); and
For Year 8 and thereafter, 50% to C and 50% to D.
You are to assume that these allocations meet the substantiality requirement.
Tier 3 Non-Recourse Liability Allocation. The partnership has elected to have all non-recourse liabilities allocated under Tier 3 to be allocated in accordance with the partners respective shares of profits. You are to assume that this means: in Years 1 through Year 7, the Tier 3 liability allocations are 25% to C and 75% to D; and in Year 8 and thereafter, the Tier 3 liability allocations are 50% to C and 50% 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 4 years of straight-line depreciation left. The fair market value of this contributed equipment, at the time of contribution, was $100, and Cs basis in the equipment was $20. The contributed equipment was subject to a non-recourse liability of $79.
D contributed $80 in cash.
During each of Year 1 and Year 2, 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 1 and Year 2, the partnership had a net loss equal to the depreciation on the contributed equipment.
The partnership did not make any distributions in either Year 1 or Year 2.
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: $80
Ds tax capital account was: $(59)
On 12/31, Year 1, the partners tax capital accounts were:
Cs tax capital account was: $
Ds tax capital account was: $
On 12/31, Year 1, the partners outside bases were:
Cs outside basis was: $
Ds outside basis was: $
On 12/31, Year 2, the partners tax capital accounts were:
Cs tax capital account was: $
Ds tax capital account was: $

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