Question
Problem below, following the determination of each of these adjustments for book purposes, set forth the effect, if any, of each of these transactions on
Problem below, following the determination of each of these adjustments for book purposes, set forth the effect, if any, of each of these transactions on Alva's and Buck's bases in their partnership interest.
Alva contributes to the partnership:
Basis FMV
Cash $50 $50
Land 100 200
(encumbered by a $100 recourse mortgage that the partnership assumes)
Buck contributes to the partnership
Bs own note 0 50
(for $50 payable in 5 years bearing interest at the AFR )
Xs note 50 50
( payable to B)
Equipment 75 100
Operating Transactions: (a) The partnership earns $600 of ordinary income under 702(a)(8).
(b) The partnership receives $100 of bond interest that is tax exempt under 103
(c)The partnership recognizes a $40 capital loss. Assume that Alvas current deduction for the loss is disallowed by 1211, whereas Bucks share of the loss is currently deductible by him in full.
(d) The partnership incurs $20 of nondeductible and noncapitalized expenditures described in 705(a)(2)(B) (e.g., "key man" term life insurance policies on the lives of partners, of which the partnership is the owner and beneficiary).
(e)The partnership borrows $100 from a bank.
(f) Subsequently, Alva assumes full liability for the $100 bank debt in (e) above, and the bank releases the partnership from liability for the amount.
(g) The partnership pays off the $100 bank debt previously assumed by Alva in (f).
(h) The partnership pays off the mortgage encumbering the land contributed by Alva.
(i) The partnership purchases common stock for $50. During the year the stock appreciates to $100, and the partnership distributes it to Alva.
(j) The partnership purchases land for $200 by paying $100 cash and giving the seller a $100 recourse purchase-money mortgage. While the land is still worth $200, the partnership distributes it to Alva, subject to the mortgage.
Does your answer depend upon whether Alva formally assumes the liability and whether the partnership is released by the lender?
(k) The partnership distributes to Buck its promissory note payable to Buck in a later year ($100 face amount with interest at the applicable federal rate).
Please provide correct solutions with detailed explanations. Thank you!
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started