Question 2

C and D each contribute $300,000 upon formation of a limited partnership. C is a general partner and D is a limited partner. The partnership purchases a commercial building on leased land for $600,000 and elects straight line cost recovery. Assume that the property has a 10 year recovery period. The CD partnership agreement allocates all items of income and loss equally with the exception of the cost recovery deductions, which are allocated entirely to D. Assume that both partners are unconditionally obligated to restore a deficit to their capital accounts upon a liquidation of the partnership.

(a)Assume that apart from cost recovery deductions, the partnership's rental income is equal to its operating expenses. What must the partner's respective capital account balances be at the end of year one if the allocation of cost recovery deductions is to have economic effect?

(b)Assume the partnership sells the building on January 1 of year two and immediately liquidates. How must the proceeds be distributed if the building is sold for $540,000? $600,000?

(c)Assume the partnership agreement further provides that gain on the disposition will be allocated to D to the extent of the cost recovery deductions specially allocated to her. What result when the partnership sells the building on January 1 of year two for $600,000?