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The Whitewater LLP is equally owned by three partners and shows the following balance sheet at the end of the current tax year. Basis FMV

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The Whitewater LLP is equally owned by three partners and shows the following balance sheet at the end of the current tax year. Basis FMV Cash $96,750 $96,750 Unrealized receivables 0 32,250 Land 32,250 129,000 $129,000 $258,000 Petula, capital $43,000 $86,000 Prudence, capital 43,000 86,000 Primrose, capital 43,000 86,000 $129,000 $258,000 Partner Petula is an active (i.e., "general") partner retiring from the service-oriented partnership. She receives $96,750 cash, none of which is stated to be for goodwill. a. How much of the payment is for "unstated goodwill"? $ b. How is the $96,750 allocated between a 736(a) income payment and a 736(b) property payment? The $96,750 cash payment is allocated as follows: $ 736(a) income payment: $ 736(b) property payment: $ Wylie is a general partner in a service providing partnership and receives cash of $204,900 in liquidation of his partnership interest, in which he has a basis of $153,675. The partnership owns no hot assets and continues in existence. After following all of the classification requirements of 736, $138,308 of this amount is classified as a property payment [ 736(b)] and $66,592 is classified as a guaranteed payment ($ 736(a)] (assume that this payment is for unstated partnership goodwill). As a result of the liquidation proceeds, how much will Wylie recognize as a capital gain or loss, and how much will be ordinary income? How much can the partnership likely deduct? Wylie recognizes a $ capital and he recognizes $ as ordinary income. The partnership can likely deduct $ which is a

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