Question
Simon is a 30 percent partner in the SBD Partnership, a calendar year-end entity. As of the end of this year, Simon has an outside
Simon is a 30 percent partner in the SBD Partnership, a calendar year-end entity. As of the end of this year, Simon has an outside basis in his interest in SBD of $188,000, which includes his share of the $60,000 of partnership liabilities. On December 31, SBD makes a proportionate distribution of the following assets to Simon:
Tax Basis | FMV | ||||
Cash | $ | 40,000 | $ | 40,000 | |
Inventory | 55,000 | 65,000 | |||
Land | 30,000 | 45,000 | |||
Totals | $ | 125,000 | $ | 150,000 | |
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a1. What are the tax consequences (amount and character of recognized gain or loss) of the distribution to Simon if the distribution is an operating distribution?
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a2. What are the tax consequences (basis in distributed assets) of the distribution to Simon if the distribution is an operating distribution?
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b1. What are the tax consequences (amount and character of recognized gain or loss) of the distribution to Simon if the distribution is a liquidating distribution?
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b2. What are the tax consequences (basis in distributed assets after allocation) of the distribution to Simon if the distribution is a liquidating distribution?
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