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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
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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