Question
The December 31 balance sheet of GST Services, LLP reads as follows. Adjusted Basis FMV Cash $300,000 $300,000 Receivables 0 150,000 Capital assets 120,000 150,000
The December 31 balance sheet of GST Services, LLP reads as follows.
Adjusted | ||
Basis | FMV | |
Cash | $300,000 | $300,000 |
Receivables | 0 | 150,000 |
Capital assets | 120,000 | 150,000 |
Total | $420,000 | $600,000 |
George, capital | $140,000 | $200,000 |
Sue, capital | 140,000 | 200,000 |
Tom, capital | 140,000 | 200,000 |
Total | $420,000 | $600,000 |
The partners share equally in partnership capital, income, gain, loss, deduction, and credit. Capital is not a material income-producing factor to the partnership, and all partners are active in the business. On December 31, general partner Sue receives a distribution of $200,000 cash in liquidation of her partnership interest under 736. Sue's outside basis for the partnership interest immediately before the distribution is $150,000. (Her basis does not correspond to her capital account because she purchased the interest a few years ago at a $10,000 premium and the partnership did not make a 754 election.) How much is Sue's gain or loss on the distribution and what is its character?
a. $40,000 capital gain; $10,000 ordinary income.
b. $40,000 ordinary income; $10,000 capital gain.
c. $50,000 ordinary income.
d. $50,000 ordinary income; $10,000 capital gain.
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