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The December 31, 2014 balance sheet of the GAB LLP is as follows: Adjusted Basis FMV Cash $300,000 $300,000 Receivables $0 $100,000 Capital assets $60,000

The December 31, 2014 balance sheet of the GAB LLP is as follows:

Adjusted Basis FMV

Cash $300,000 $300,000

Receivables $0 $100,000

Capital assets $60,000 $80,000

Total $360,000 $480,000

Gina, capital $90,000 $120,000

Adelle, capital $180,000 $240,000

Britney, capital $90,000 $120,000

Total $360,000 $480,000

Capital is not a material income-producing factor for the LLP. Gina is an active partner and owner of a 25% interest in the LLPs profits and capital. On December 31, 2014, Gina receives a distribution of $140,000 cash in liquidation of her partnership interest under section 736. Nothing is stated in the partnership agreement about goodwill. Ginas outside basis for the partnership interest immediately before the distribution is $90,000.

Instead Gina sells her partnership interest to Jess for $140,000 of cash.

A. What is the amount and character of Ginas gain?

B. What deductions can be claimed by the LLP?

C. What action might Jess request of the partnership?

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