Question

interest is $50,000. His distribution includes cash of $5,000, inventory (FMV -$20,000; basis $10,000), and equipment (FMV $2,000; basis $1,000). Sam's marginal tax rate is 24% and his long-term capital gains tax rate is 15%. 2. Sam receives a proportionate nonliquidating distribution when the basis of his partnership a. How much gain or loss does Sam recognize? Gain /Loss) b. What is Sam's tax liability/benefit on the distribution? (Liability /Benefit) c. What is Sam's basis in the inventory? d. What is Sam's basis in the equipment? e. What is Sam's remaining basis in the partnership?

Answer 1

When property is distributed to a partner, then the partnership must treat it as a sale at fair market value (FMV). The partner's capital account is decreased by the FMV of the property distributed. The book gain or loss on the constructive sale is apportioned to each of the partners' accounts.

The inside basis is the partnership's tax basis in the individual assets. The outside basis is the tax basis of each individual partner's interest in the partnership. When a partner contributes property to the partnership, the partnership's basis in the contributed property is equal to its fair market value (FMV). However, the outside basis of the partner increases only by the amount of the basis that the partner had in the property.

34800

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