Question
On May 31, six brothers decided to form the Gale Brothers Partnership to publish and print children's stories. The contributions of the brothers and their
On May 31, six brothers decided to form the Gale Brothers Partnership to publish and print children's stories. The contributions of the brothers and their partnership interests are listed below. They share the economic risk of loss from liabilities according to their partnership interests.
Basis
Partnership
Individual
Asset
to Partner
FMV
Interest
Adam
Cash
$60,000
$60,000
20%
Brian
Accounts receivable
0
45,000
15%
Chance
Office equipment
13,000
15,000
5%
Dale
Land
80,000
30,000
10%
Earl
Building
30,000
190,000
30%
Flash
Services
?
60,000
20%
Brian contributes accounts receivable from his proprietorship, which uses the cash method of accounting. | |
Chance uses the office equipment in a small business he owns. When he joins the partnership, he sells the remaining business assets to an outsider. He has claimed $8,000 of MACRS depreciation on the office equipment. | |
The partnership assumes a $100,000 mortgage on the buildingEarl contributes.Earl claimed$90,000 of straight-line MACRS depreciation on the commercial property. | |
Flash, an attorney, drew up all the partnership agreements and filed the necessary paperwork. He receives a full20% capital and profits interest for his services.
| |
a. | How much gain, loss, or income must each partner recognize as a result of theformation? |
b. | How much gain, loss, or income must the partnership recognize as a result of the formation? |
c. | What is each partner's basis in his partnership interest? |
d. | What is the partnership's basis in its assets? |
e. | What is the partnership's initial book value of each asset? |
f. | What effects do the depreciation recapture provisions have on the propertycontributions? |
g. | How would your answer to Part a change if Flash received only a profitsinterest? |
h. | What are the tax consequences to the partners and the partnership when the partnership sells for $21,000 the land contributed byDale? Prior to the sale, the partnership held the land as an investment for two years. |
a. | How much gain, loss, or income must each partner recognize as a result of theformation? |
b. | How much gain, loss, or income must the partnership recognize as a result of the formation? |
c. | What is each partner's basis in his partnership interest? |
d. | What is the partnership's basis in its assets? |
e. | What is the partnership's initial book value of each asset? |
f. | What effects do the depreciation recapture provisions have on the propertycontributions? |
g. | How would your answer to Part a change if Flash received only a profitsinterest? |
h. | What are the tax consequences to the partners and the partnership when the partnership sells for $21,000 the land contributed byDale? Prior to the sale, the partnership held the land as an investment for two years. |
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