Question
The RST Partnership makes a proportionate distribution of its assets to Ryan, in complete liquidation of his partnership interest. The distribution consists of $40,000 in
The RST Partnership makes a proportionate distribution of its assets to Ryan, in complete liquidation of his partnership interest. The distribution consists of $40,000 in cash and capital assets with a basis to the partnership of $30,000 and a fair market value of $48,000. None of the payment is for partnership goodwill. At the time of the distribution, Ryans partnership basis is $45,000 and the partnership has no liabilities and no hot assets. If the partnership has made a 754 optional basis adjustment election on a timely filed return, with regard to the partnership's liquidating distribution to Ryan, what are the income tax consequences to Ryan and the RST Partnership?
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