What is the outside and inside basis for each tax partner upon formation? What is the effect and difference of Claire's alternatives on the partnership?
What is the outside and inside basis for each tax partner upon formation? What is the effect and difference of Claire's alternatives on the partnership?
Profits and losses are decided to be shared equally. They also wish to have their initial capital in the partnership to be $10,000 each. All three partners are skilled plumbers and will perform services as co-proprietors in the new partnership. Eb, the partner with the most liquid assets, will contribute $10,000 in cash. Ralph, who previously conducted his plumbing business as a sole proprietor, contributes $5,000 of zero-basis accounts receivable and $5,000 of installment notes with a $1,000 basis. Claire, who previously worked for her father before his retirement last year, contributes trucks and equipment. These assets were given to Alf when her father retired. The equipment and trucks have an aggregate adjusted basis of $2,000 and a fair market value of $9,000. To make up for the $1,000 of capital shortage Claire has suggested one of two alternatives.
#1 - Claire contributes fifteen faucets and knobs she had made by hand over the past two years in her spare time. The designs are new and have never been marketed in the trade. However, if this design catches on as a fad, the partnership will make a substantial amount of money. Her tax basis comes to $500 (the raw materials involved); Eb and Ralph agree that the items are worth $1,000 and will credit her capital with $1,000.
#2 - Claire contributes a letter of commitment to perform all of the plumbing work in a proposed shopping center. Unfortunately, the commitment grants the contract to the fathers business and does not say whether a business without Claires father could be appointed to do the job. This letter (along with all the other assets) was given to Claire when her father retired. Claire's basis in the letter is zero. As with the faucets and knobs, Eb and Ralph agree that the commitment's fair market value equals $1,000 and Claires capital account will be credited with this value.
(This is all the info given and be enough to answer! I will upvote)
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