Mickey, Don, and Derek are equal (1/3rd) partners in River Avenue, LLC. Mickey’s outside basis in his partnership interest is $250.  River Avenue’s balance sheet (including FMV) is below.  Mickey sells his interest to Roger for $500 cash + debt assumption.  *Assume that River Avenue originally purchased the machinery for $120 (i.e., accumulated depreciation = $65), and that $120 of depreciation has been taken on the building since its acquisition five years ago*   Assets   FMV     Book Tax Debt Book Tax Cash 240 240 240 Recourse 150 150 A/R 60 75        75       Inventory 150 90 90 Capital     Machinery 100 55 55 Mickey 200 200 Building 500 200 200 Don 200 200 Stock 300 90        90 Derek 200 200 Goodwill 300 0 0         What is Roger’s initial outside basis and what is the balance in his capital accounts?   If a section 754 election is made, what is the amount of the section 743(b) adjustment?   How is the section 743(b) adjustment allocated among the partnership’s assets?

SWFT Essntl Tax Individ/Bus Entities 2020
23rd Edition
ISBN:9780357391266
Author:Nellen
Publisher:Nellen
Chapter14: Partnerships And Limited Liability Entities
Section: Chapter Questions
Problem 20P
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  1. Mickey, Don, and Derek are equal (1/3rd) partners in River Avenue, LLC. Mickey’s outside basis in his partnership interest is $250.  River Avenue’s balance sheet (including FMV) is below.  Mickey sells his interest to Roger for $500 cash + debt assumption.  *Assume that River Avenue originally purchased the machinery for $120 (i.e., accumulated depreciation = $65), and that $120 of depreciation has been taken on the building since its acquisition five years ago*

 

Assets  

FMV    

Book

Tax

Debt

Book

Tax

Cash

240

240

240

Recourse

150

150

A/R

60

75       

75

 

 

 

Inventory

150

90

90

Capital

 

 

Machinery

100

55

55

Mickey

200

200

Building

500

200

200

Don

200

200

Stock

300

90       

90

Derek

200

200

Goodwill

300

0

0

 

 

 

 

  1. What is Roger’s initial outside basis and what is the balance in his capital accounts?

 

  1. If a section 754 election is made, what is the amount of the section 743(b) adjustment?

 

  1. How is the section 743(b) adjustment allocated among the partnership’s assets?
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