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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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