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Problem 5. Four years ago, Leona, Harry, and Jeremiah formed an equal partnership to which Leona contributed Blackacre (value = $1000, basis = $600), Harry

Problem 5. Four years ago, Leona, Harry, and Jeremiah formed an equal partnership to which Leona contributed Blackacre (value = $1000, basis = $600), Harry contributed nonmarketable securities (value = $1000, basis = $200), and Jermiah contributed $1000 cash. The partnership used the cash to buy Greenacre. All three assets are capital assets in the partnerships hands. On January 1 of this year, the partnerships balance sheet is as follows:

Asset

Basis

Book

FMV

Blackacre

$600

$1000

$1500

Greenacre

1000

1000

1500

Securities

200

1000

1500

Capital Accounts

Tax Book

Leona

$600 $1000

Harry

200 1000

Jeremiah

1000 1000

On the current date, the following alternative distributions take place. What are the tax consequences to all parties of each of distribution?

(a) Jeremiah receives Blackacre in complete liquidation of his interest in the partnership. How would your answer change, if at all, if Blackacre were worth only $800 on the date of distribution?

(b) Harry receives Greenacre in complete liquidation of his interest in the partnership.

(c) Harry receives Blackacre in complete distribution of his interest in the partnership.

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