Pedro owns a 60% interest in the PD General Partnership having a $40,000 basis and $200,000 FMV. His share of partnership liabilities is $100,000. Because he is nearing retirement age, he has decided to give away his partnership interest on June 15 of the current year. The partnerships tax year ends on December 31. Pedros tax year ends on June 30. He intends to give a 30% interest to his son, Juan, and the remaining 30% interest to the American Red Cross.

Required: A tax manager in your firm has asked you to prepare a letter to Pedro explaining fully the tax consequences of this gift to him, the partnership, and the donees. She reminds you to be sure to include information about the allocation of the current years partnership income.