Question
Please respond to the following adhering to current U.S. Tax Law: -Abby is a partner in a partnership. She receives a non-liquidating distribution consisting of
Please respond to the following adhering to current U.S. Tax Law:
-Abby is a partner in a partnership. She receives a non-liquidating distribution consisting of three assets: Cash $100 Inventory $40 tax basis; $45 fmv Land $170 tax basis; $250 fmv Abby's outside basis in the partnership at the time of the distribution was $300. You can assume that there was no pre-contribution gain (i.e., built-in gain) in the inventory or land.
a. How much gain or loss does the partnership recognize?
b. How much gain or loss does Abby recognize as a result of the distribution?
c. After the distribution, what is Abby's tax basis in the inventory she receives?
d. After the distribution, what is Abby's tax basis in the land she receives?
e. After the distribution, what is Abby's tax basis in her partnership interest (i.e., outside basis)?
-Assume an LLC has the following balance sheet immediately before a disproportionate liquidating distribution: Basis FMV Cash $9,000 $9,000 Inventory $3,600 $4,500 Members A, B, and C are each one-third members of the LLC. There is no Section 704(c) built-in gain associated with the inventory. In the disproportionate distribution, A receives $4,500 in cash and B receives $4,500 in cash. C receives the inventory. Assume that all of the members have enough outside basis that the distribution does not exceed their outside basis.
a. How much ordinary income does A recognize because of the disproportionate distribution?
b. What is C's tax basis in the inventory after the distribution?
-Abby is a partner in a partnership. She receives a liquidating distribution as follows: Cash $100 Inventory $40 tax basis; $45 fmv Land $170 tax basis; $250 fmv Abby's outside basis in the partnership at the time of the distribution was $300. You can assume that there was no pre-contribution gain (i.e., built-in gain) or loss in the inventory or land.
a. How much gain or loss does the partnership recognize?
b. How much gain or loss does Abby recognize as a result of the distribution?
c. After the distribution, what is Abby's tax basis in the inventory she receives?
d. After the distribution, what is Abby's tax basis in the land she receives?
e. After the distribution, what is Abby's tax basis in her partnership interest (i.e., outside basis)?
f. Assume instead of the original facts that Abby only receives the cash and inventory (and no land) in the liquidating distribution. How much gain or loss would Abby recognize?
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