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W, X, Y and Z each contribute $200,000 for a 25% interest in the W, X, Y and Z partnership. The partners all meet the
W, X, Y and Z each contribute $200,000 for a 25% interest in the W, X, Y and Z partnership. The partners all meet the 3 tests for economic effect and the tests for allocation of non-recourse debt. The partnership uses the $800,000 cash plus a non- recourse loan to buy a building for $4,000,000. The building is depreciable over 20 years on a straight- line basis. Income for all years equals expenses except for tax depreciation which is allocated all to W. a) How much depreciation will W be allowed to take in year 1? b) How much depreciation will W be allowed to take in year 2? c) What effect, if any, would a negative capital account have on W's ability to take depreciation deductions? d) What is Ws tax basis in his partnership interest after year 1? After year 2
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