Steve, Karen, David, and Ellen form a general partnership to acquire a building in Boca Raton, Florida. The partnership plans to renovate the building. The partnership hopes to either sell the building at a profit or lease it. Steve, Karen, David, and Ellen each contribute $10,000 to the partnership. The partnership borrows $960,000 on a recourse basis. Under the applicable state general partnership act, all the partners are jointly and severally liable for all recourse debts; however, their agreement for bearing losses determines which one of them bears the ultimate loss with respect to one another. The partnership uses the capital contributions and the loan proceeds to acquire the building and complete the renovations.

a. If the partners agree to share all profits and bear all losses equally, what are their shares of the partnership’s $960,000 recourse liability?

b. Suppose the partners agree the partners agree that all profits will be allocated equally but losses will be allocated 70% to Steve, 20% to Karen, and5% each to David and Ellen. What are the partner’s shares of the $960,000 recourse debt?

c. Assume the same loss-sharing ratios in Question 6b. What are the partners’ outside bases if Steve is entitled to seek reimbursement from Ellen or, alternatively, Ellen’s wholly owned corporation, which has only nominal assets, to the extent his losses exceed $10,000? What if Ellen holds her partnership interest through a wholly owned LLC, which has no assets other than the partnership interest and the existence of which is dis-regarded for tax purposes, and Steve is entitled to seek reimbursement from the LLC?

d. What are the partners’ outside bases if Steve lends the partnership $960,000 on a recourse basis? Assume equal sharing of profits and losses.

e. Assume the same facts as in Question 6a, except that the partnership borrowed $960,000 nonrecourse basis (the lender’s only recourse is to foreclose on the building if the partnership cannot pay; in other words, no partner (or related person) bears the economic risk of loss). What is each partner’s outside basis?

f. How would the answer to Question 6e change if David guaranteed the entire $960,000 nonrecourse liability? What if the guarantor were David’s father, David’s sister, or a partnership in which David owns 80% of the capital and profits?