A is a one-third partner in Partnership ABC. A sells his one-third interest in ABC to D on January 1 of the current year for $200,000. ABC is a cash-method, calendar year partnership. ABC does not have a section 754 election in effect. The balance sheet of ABC is as follows: Assets:     Basis:     FMV: Cash     10000         10000 A/R        0                  50000 Inv.        30000          40000 PPE      150000        200000 Goodwill 210000       400000 Total:      400000        700000 Liabilities: 100000     100000 Capital-A  100000      200000 Capital-B. 100000      200000 Capital-C. 100000      200000 Total:         400000     700000 $150,000 of depreciation was taken on the furniture, fixtures, and equipment, and thus the original basis was $300,000. Assume for the sake of the problem that the outside basis of the partners in their partnership interests (without taking into consideration their allocable share of debt under I.R.C section 752) is equal to their capital as shown on the balance sheet. a. What is A's amount realized and gain recognized? What is the character of A's gain? b. What is D's basis for her partnership interest?

SWFT Comprehensive Volume 2019
42nd Edition
ISBN:9780357233306
Author:Maloney
Publisher:Maloney
Chapter21: Partnerships
Section: Chapter Questions
Problem 28P
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A is a one-third partner in Partnership ABC. A sells his one-third interest in ABC to D on January 1 of the current year for $200,000. ABC is a cash-method, calendar year partnership. ABC does not have a section 754 election in effect. The balance sheet of ABC is as follows:

Assets:     Basis:     FMV:

Cash     10000         10000
A/R        0                  50000
Inv.        30000          40000
PPE      150000        200000
Goodwill 210000       400000
Total:      400000        700000

Liabilities: 100000     100000

Capital-A  100000      200000
Capital-B. 100000      200000
Capital-C. 100000      200000
Total:         400000     700000

$150,000 of depreciation was taken on the furniture, fixtures, and equipment, and thus the original basis was $300,000. Assume for the sake of the problem that the outside basis of the partners in their partnership interests (without taking into consideration their allocable share of debt under I.R.C section 752) is equal to their capital as shown on the balance sheet.

a. What is A's amount realized and gain recognized? What is the character of A's gain?

b. What is D's basis for her partnership interest?

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