CHAPTER 21 PARTNERSHIPS

1. George and James are forming the GJ Partnership. George contributes $600,000 cash and James contributes nondepreciable property with an adjusted basis of $400,000 and a fair market value of $750,000. The property is subject to a $150,000 liability, which is also transferred into the partnership and is shared equally by the partners for basis purposes. George and James share in all partnership profits equally except for any precontribution gain, which must be allocated according to the statutory rules for built-in gain allocations.

a. What is James’s adjusted tax basis for his partnership interest immediately after the partnership is formed?

b. What is the partnership’s adjusted basis for the property contributed by James?

c. If the partnership sells the property contributed by James for $800,000, how is the tax gain allocated between the partners?

2. Palmer contributes property with a fair market value of $4,000,000 and an adjusted basis of $3,000,000 to AP Partnership. Palmer shares in $1,000,000 of partnership debt under the liability sharing rules, giving him an initial adjusted basis for his partnership interest of $4,000,000. One month after the contribution, Palmer receives a cash distribution from the partnership of $2,000,000. Palmer would not have contributed the property if the partnership had not contractually obligated itself to make the distribution. Assume Palmer’s share of partnership liabilities will not change as a result of this distribution.

a. Under the IRS’s likely treatment of this transaction, what is the amount of gain or loss that

Palmer will recognize because of the $2,000,000 cash distribution?

b. What is the partnership’s basis for the property after the distribution?

c. If Palmer is unhappy with this result, can you suggest a possible alternative that may provide him with a better answer?

3. During the current year, MAC Partnership reported the following items of receipts and expenditures: $600,000 sales, $80,000 utilities and rent, $200,000 salaries to employees, $20,000 guaranteed payment to partner Antonio, investment interest income of $4,000, a charitable contribution of $8,000, and a distribution of $30,000 to partner Carl. Antonio is a 25% general partner. Based on this information, what items will be reflected on Antonio’s Schedule K-1?

4. The LN partnership reported the following items of income and deduction during the current tax year: revenues,

$300,000; cost of goods sold, $180,000; tax-exempt interest income, $2,000; salaries to employees, $80,000; and long-term capital gain, $10,000. In addition, the partnership distributed $20,000 of cash to 50% partner Nina and $10,000 of cash to 50% partner Len. What is Nina’s share of ordinary partnership income and separately stated items?

5. Carli contributes land to the newly formed CD Partnership in exchange for a 30% interest. The land has an adjusted basis and fair market value of $300,000 and is subject to a liability of $100,000, which the partnership assumes. None of this liability is repaid at year-end. At the end of the year, the partnership has trade accounts payable of $20,000. Assume all liabilities are allocated proportionately to the partners. Total partnership income for the year is $400,000. What is Carli’s basis in her partnership interest at the end of the year?