Exam 11: Partnerships Distributions Transfer of Interests and Terminations

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Which of the following distributions would never result in gain recognition to the recipient partner?

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Hannah sells her 25% interest in the HIJK Partnership to Alyssa for $120,000 cash. At the end of the year prior to the sale, Hannah's basis in HIJK was $70,000. The partnership allocates $15,000 of income to Hannah for the portion of the year she was a partner. On the date of the sale, the partnership assets and the agreed fair market values were as follows. Adjusted Cash \ 100,000 \ 100,000 Accounts Receivable -0- 80,000 Land 240,000 220,000 Total \ 340,000 \ 400,000 Determine the amount and character of any gain that Hannah recognizes on the sale.

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Anthony's basis in the WAM Partnership interest was $200,000 just before he received a proportionate liquidating distribution consisting of investment land (basis of $90,000, fair market value of $100,000), and inventory (basis of $30,000, fair market value of $70,000). After the distribution, Anthony's recognized gain or loss and his basis in the land and inventory are:

(Multiple Choice)
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Alyce owns a 30% interest in a continuing partnership. The partnership distributes a $35,000 year-end cash payment to Alyce. In a proportionate nonliquidating distribution, the partnership also distributed property (basis of $20,000, fair market value of $30,000) to Alyce. Immediately before the distributions of cash and property, Alyce's basis in the partnership interest was $60,000. As a result of the distribution, Alyce recognizes:

(Multiple Choice)
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Susan is a one-fourth limited partner in the SJ Partnership in which capital is not a material income-producing factor. Partnership assets consist of land (fair market value of $100,000, basis of $80,000), accounts receivable (fair market value of $100,000, basis of $0) and cash of $200,000. SJ distributes $100,000 of the cash to Susan in liquidation of her interest. Susan's basis in the partnership interest was $70,000 immediately before the distribution. How much gain or loss does Susan recognize and what is its character? How much can the partnership deduct?

(Essay)
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Brittany, Jennifer, and Daniel are equal partners in the BJD Partnership. The partnership balance sheet reads as follows on December 31 of the current year. Adjusted Basis F M V Cash \ 75,000 \ 75,000 Unrealized receivables -0- 51,000 Land Total \ Brittany, capital \ 40,000 \6 3,000 Jennifer, capital 40,000 63,000 Daniel, capital 40,000 63,000 Total Partner Daniel has an adjusted basis of $40,000 for his partnership interest. If Daniel sells his entire partnership interest to new partner Amber for $73,000 cash, how much can the partnership step-up the basis of Amber's share of partnership assets under §§ 754 and 743(b)?

(Multiple Choice)
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Match the following statements with the best match from the choices below. Note: Choice L may be used more than once. -Potential depreciation recapture

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The BLM LLC's balance sheet on August 31 of the current year is as follows. Adjusted Basis F M V Cash \ 60,000 \ 60,000 Receivables -0- 150,000 Capital assets 90,000 300,000 Nonrecourse debt \ 90,000 \ 90,000 Barney, capital 20,000 140,000 Lillie, capital 20,000 140,000 Marshall, capital 20,000 The nonrecourse debt is shared equally among the LLC members. On that date, Lillie sells her one-third interest to Robyn for $170,000, including cash and relief of Lillie's share of the nonrecourse debt. Lillie's outside basis for her interest in the LLC is $50,000, including her share of the LLC's debt. How much capital gain and/or ordinary income will Lillie recognize on the sale?

(Multiple Choice)
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The RST Partnership makes a proportionate distribution of its assets to Ryan, in complete liquidation of his partnership interest. The distribution consists of $40,000 in cash and capital assets with a basis to the partnership of $30,000 and a fair market value of $48,000. None of the payment is for partnership goodwill. At the time of the distribution, Ryan's partnership basis is $45,000 and the partnership has no liabilities and no "hot assets." If the partnership makes an optional basis adjustment election on a timely filed return, the partnership recognizes:

(Multiple Choice)
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Which of the following transactions will not result in termination of a partnership for Federal tax purposes?

(Multiple Choice)
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Lori, a partner in the JKL partnership, received a proportionate nonliquidating distribution of $10,000 cash, unrealized receivables with a basis of $0 and a fair market value of $15,000, and land with a basis of $6,000 and a fair market value of $10,000. Her basis in the partnership interest immediately before the distributions was $14,000. She will recognize $0 gain on the distribution, and her basis in the receivables and land will be $0 and $4,000, respectively.

(True/False)
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Match the following statements with the best match from the choices below. Note: Choice L may be used more than once. -Unrealized receivable

(Multiple Choice)
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Tom, Tina, Tatum, and Terry are equal owners in the 4-Ts LLC, a cash basis service entity. 4-Ts has unrealized receivables of $400,000 (basis of $0), and no other hot assets. A goodwill payment of $50,000 per partner is provided for in the LLC's operating agreement. If 4-Ts distributes cash of $300,000 to Tom in liquidation of his LLC interest, which of the following statements is correct?

(Multiple Choice)
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Matt, a partner in the MB Partnership, receives a proportionate, nonliquidating distribution of property having a fair market value of $16,000 and a partnership basis of $23,000. Matt's basis in the partnership is $10,000 before the distribution. In this situation, Matt will recognize no gain or loss. He will take a $10,000 basis in the property, and his basis in the partnership interest is reduced to zero.

(True/False)
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Suzy owns a 30% interest in the JSD LLC. In liquidation of the entity, Suzy receives a proportionate distribution of $30,000 cash, inventory (basis of $16,000, fair market value of $18,000), and land (basis of $25,000, fair market value of $30,000). Suzy's basis in the entity immediately before the distribution was $80,000. As a result of the distribution, what is Suzy's basis in the inventory and land, and how much gain or loss does she recognize?

(Multiple Choice)
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Match the following statements with the best match from the choices below. Note: Choice L may be used more than once. -Ordering rules

(Multiple Choice)
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Match the following independent distribution payments in liquidation of a partner's interest in an ongoing partnership with the statements below. -Distribution of cash of $25,000 for a partner's share of substantially appreciated inventory.

(Multiple Choice)
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In a proportionate liquidating distribution in which the partnership is also liquidated, Ralph received cash of $30,000, accounts receivable (basis of $0, fair market value of $20,000), and land (basis of $1,000, fair market value of $10,000). Immediately before the distribution, Ralph's basis in the partnership interest was $40,000. Ralph realizes and recognizes a loss of $9,000, and his basis is $0 in the accounts receivable and $1,000 in the land.

(True/False)
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Match the following statements with the best match from the choices below. Note: Choice L may be used more than once. -Optional adjustment election

(Multiple Choice)
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Match the following independent descriptions as "hot" (i.e., ordinary income-producing) or nonhot assets with the statements below. -Inventory with a basis of $10,000 and a fair market value of $15,000.

(Multiple Choice)
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