Question
The GL limited partnership was organized at the beginning of the current year. G, the general partner, contributed $10 for a 10 percent interest in
The GL limited partnership was organized at the beginning of the current year. G, the general partner, contributed $10 for a 10 percent interest in profits, losses and capital, and L, as limited partner, received a 90 percent interest in profits, losses and capital in exchange for a capital contribution of $90. The partnership immediately purchased a rental apartment building for $1,000, paying $100 in cash and issuing a $900 purchase money note, with interest payable currently and a lump-sum principal payment due in 20 years. Determine each partners initial outside basis under each of the following alternatives:
4. Defining and Sharing Nonrecourse liabilities. Assume that the $900 note in problem 3 is nonrecourse (i.e., it is secured by the apartment building but neither the partnership nor either of its partners has any personal liability on the note).
(a) Determine each partner's initial outside basis in the partnership. (b) Same as (a), except that L pledged IBM stock (basis $100, value $200) to secure the loan?
(c) Same as (a), except that L guaranteed the note in a side agreement with the holder?
(d) Same as (a), except that L guaranteed the holder that it would receive a minimum of $200?
(e) Same as (a), except that the partnerships note is guaranteed, alternatively, by:
i. Gs wholly owned corporation?
ii. Ls father?
iii. Gs sister?
iv. Another partnership in which L is an 80% partner? o
r v. A partner of L in another partnership?
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