Question
Smith, Jones, and Green are to be equal general partners in the SJG partnership. Smith transferred land with an adjusted basis of $820,000 and a
Smith, Jones, and Green are to be equal general partners in the SJG partnership. Smith transferred land with an adjusted basis of $820,000 and a FMV of $1,800,000 to the partnership. At the time of transfer, the land was encumbered by a $1,200,000 recourse debt, which had been incurred 7 years earlier. Jones contributed cash of $600,000 and Green contributed cash of $450,000 to the partnership.
a. What is the partnership's inside basis in the land?
b. What is Smiths capital account balance and his outside basis in his partnership interest?
c. What is Jones capital account balance and his outside basis in his partnership interest?
d. What amount of gain or loss, if any, must Smith recognize as a consequence of the above transfer?
Assume instead that the liability was a non-recourse debt
e. What is Smiths capital account balance and his outside basis in his partnership interest?
f. What is Greens capital account balance and his outside basis in his partnership interest?
g. What amount of gain or loss, if any, must Smith recognize as a consequence of the above transfer?
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