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PIB Partnership is owned 20% by Sara, 40% by Steve, and 40% by Thann. Burnham, Inc. is owned 70% by PIB Partnership, 10% by Ralph,
PIB Partnership is owned 20% by Sara, 40% by Steve, and 40% by Thann. Burnham, Inc. is owned 70% by PIB Partnership, 10% by Ralph, 10% by Thann, and 10% by Sara. Ralph and Thann are brothers. All other individuals are unrelated. During the current year, Ralph sold a piece of land to Burnham, Inc., for $90,000. Ralph originally purchased the land as an investment a few years ago for $100,000. Read the equirements Requirement a. How much of the loss may Ralph recognize? Begin by determining Ralph's constructive ownership in Burnham, Inc. (Enter percentages as whole numbers.) Direct ownership of Burnham, Inc. by Ralph % Through Thann: Thann's actual ownership % Thann's ownership through PIB % % Total % How much of the loss may Ralph recognize? (Assume that Ralph has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) The realized loss is $ Under the related party rules (Sec. 267), since Ralph to recognize this loss on the sale of land to Burnham Inc. of Burnham Inc. he Requirement b. Now assume all the same facts except that the sale occurred between Thann and Burnham, Inc. How much of the loss may Thann recognize? Begin by determining Thann's constructive ownership in Burnham, Inc. (Enter percentages as whole numbers.) % Direct ownership of Burnham, Inc. by Thann Through Ralph Through PIB to himself % % Through PIB to his partners Through Sara, his partner % Total % How much of the loss may Thann recognize? (Assume that Thann has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) Under the related party rules (Sec. 267), since Thann constructively of Burnham Corporation, he to recognize this loss on the sale of land to Burnham Corporation. Requirement c. Now assume the same facts as in b except that Burnham, Inc., is owned 60% by Sara and 40% by Ralph. Thann sells the land to Burnham, Inc. How much of the loss may Thann recognize? (Assume that Thann has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) In this case, Thann is treated Thus, Thann to recognize this loss on the sale of land to Burnham, Inc. i Requirements -X a. b. How much of the loss may Ralph recognize? Now assume all the same facts except that the sale occurred between Thann and Burnham, Inc. How much of the loss may Thann recognize? Now assume the same facts as in b except that Burnham, Inc., is owned 60% by Sara and 40% by Ralph. Thann sells the land to Burnham, Inc. How much of the loss may Thann recognize? c. Print Done PIB Partnership is owned 20% by Sara, 40% by Steve, and 40% by Thann. Burnham, Inc. is owned 70% by PIB Partnership, 10% by Ralph, 10% by Thann, and 10% by Sara. Ralph and Thann are brothers. All other individuals are unrelated. During the current year, Ralph sold a piece of land to Burnham, Inc., for $90,000. Ralph originally purchased the land as an investment a few years ago for $100,000. Read the equirements Requirement a. How much of the loss may Ralph recognize? Begin by determining Ralph's constructive ownership in Burnham, Inc. (Enter percentages as whole numbers.) Direct ownership of Burnham, Inc. by Ralph % Through Thann: Thann's actual ownership % Thann's ownership through PIB % % Total % How much of the loss may Ralph recognize? (Assume that Ralph has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) The realized loss is $ Under the related party rules (Sec. 267), since Ralph to recognize this loss on the sale of land to Burnham Inc. of Burnham Inc. he Requirement b. Now assume all the same facts except that the sale occurred between Thann and Burnham, Inc. How much of the loss may Thann recognize? Begin by determining Thann's constructive ownership in Burnham, Inc. (Enter percentages as whole numbers.) % Direct ownership of Burnham, Inc. by Thann Through Ralph Through PIB to himself % % Through PIB to his partners Through Sara, his partner % Total % How much of the loss may Thann recognize? (Assume that Thann has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) Under the related party rules (Sec. 267), since Thann constructively of Burnham Corporation, he to recognize this loss on the sale of land to Burnham Corporation. Requirement c. Now assume the same facts as in b except that Burnham, Inc., is owned 60% by Sara and 40% by Ralph. Thann sells the land to Burnham, Inc. How much of the loss may Thann recognize? (Assume that Thann has sufficient capital gains in the current year to absorb the full amount of any capital losses that may potentially be recognized.) In this case, Thann is treated Thus, Thann to recognize this loss on the sale of land to Burnham, Inc. i Requirements -X a. b. How much of the loss may Ralph recognize? Now assume all the same facts except that the sale occurred between Thann and Burnham, Inc. How much of the loss may Thann recognize? Now assume the same facts as in b except that Burnham, Inc., is owned 60% by Sara and 40% by Ralph. Thann sells the land to Burnham, Inc. How much of the loss may Thann recognize? c. Print Done
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