Exam 11: Partnerships: Distributions, transfer of Interests, and Terminations

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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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In a proportionate nonliquidating distribution of a capital asset,the partner recognizes gain to the extent the fair market value of the asset exceeds the partnership's basis in the asset.

(True/False)
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The LMO Partnership distributed $30,000 cash to Laura in a proportionate,nonliquidating distribution.Laura's basis in her partnership interest was $25,000 immediately before the distribution.As a result of the distribution,Laura's basis is reduced to ($5,000)(negative)and she recognizes no gain or loss.

(True/False)
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Cynthia sells her 1/3 interest in the CAR Partnership to Brandon for $80,000 cash.Brandon also assumed Cynthia's 1/3 share of partnership liabilities.On the date of sale,the partnership balance sheet and agreed-upon fair market values were as follows: Cynthia sells her 1/3 interest in the CAR Partnership to Brandon for $80,000 cash.Brandon also assumed Cynthia's 1/3 share of partnership liabilities.On the date of sale,the partnership balance sheet and agreed-upon fair market values were as follows:   If the partnership has a § 754 election in effect,the total step-up in basis that Brandon can take in the partnership assets is: If the partnership has a § 754 election in effect,the total "step-up" in basis that Brandon can take in the partnership assets is:

(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 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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The MBC Partnership makes a § 736(b)cash payment of $50,000 to partner Betty in liquidation of her interest in the partnership.The partnership owns no hot assets.Betty's basis in her partnership interest before the distribution was $20,000.If the partnership has a § 754 election in effect,it will record a $30,000 decrease in its inside basis in partnership assets,allocable to the remaining partners in the partnership.

(True/False)
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A disproportionate distribution arises when the partnership distributes a share of partnership hot assets to one or more partners that is not the same as the partner's ownership interest in the partnership.

(True/False)
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Last year,Oscar contributed nondepreciable property with a basis of $40,000 and a fair market value of $50,000 to the Starling Partnership in exchange for a 25% interest in the partnership.In the current year,he receives a nonliquidating distribution from the partnership of other property with a basis to the partnership of $26,000 and a fair market value of $32,000.The basis in his partnership interest at the time of the distribution was $30,000.How much gain or loss does Oscar recognize on the distribution? (Assume no other distributions have been made to Oscar,the property he originally contributed is still owned by the partnership,and this is not a disguised sale transaction. )

(Multiple Choice)
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A payment to a retiring partner for his or her share of goodwill of a partnership in which capital is a material income-producing factor is classified as a § 736(a)income payment and results in ordinary income to the retiring partner and a current deduction to the partnership.

(True/False)
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Jackie owns a 40% interest in the capital and profits of the JAJ Partnership.Immediately before she receives a proportionate nonliquidating distribution from JAJ,the basis of her partnership interest is $40,000.The distribution consists of $20,000 in cash and land with a fair market value of $30,000.JAJ's adjusted basis in the land immediately before the distribution is $25,000.As a result of the distribution,Jackie recognizes no gain or loss and her basis in the land is $20,000.

(True/False)
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At the beginning of the year,Elsie's basis in the E&G Partnership interest is $60,000.She receives a proportionate nonliquidating distribution from the partnership consisting of $10,000 of cash,unrealized accounts receivable (basis of $0,fair market value $30,000),and inventory (basis of $10,000,fair market value of $20,000).After the distribution,Elsie's bases in the accounts receivable,inventory,and partnership interest are:

(Multiple Choice)
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Suzy owns a 25% capital and profits interest in the calendar-year SJDV Partnership.Her adjusted basis for her partnership interest on July 1 of the current year is $200,000.On that date,she receives a proportionate nonliquidating current distribution of the following assets: Suzy owns a 25% capital and profits interest in the calendar-year SJDV Partnership.Her adjusted basis for her partnership interest on July 1 of the current year is $200,000.On that date,she receives a proportionate nonliquidating current distribution of the following assets:       Suzy owns a 25% capital and profits interest in the calendar-year SJDV Partnership.Her adjusted basis for her partnership interest on July 1 of the current year is $200,000.On that date,she receives a proportionate nonliquidating current distribution of the following assets:

(Essay)
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The December 31,2010,balance sheet of the calendar-year JKL Partnership reads as follows. The December 31,2010,balance sheet of the calendar-year JKL Partnership reads as follows.     Each partner shares in 1/3 of the partnership capital,income,gain,loss,deduction and credit.On December 31,2010,Jan sells her 1/3 partnership interest to Jennifer for $43,000 cash.Assume the partnership makes a § 754 election for 2010.   Each partner shares in 1/3 of the partnership capital,income,gain,loss,deduction and credit.On December 31,2010,Jan sells her 1/3 partnership interest to Jennifer for $43,000 cash.Assume the partnership makes a § 754 election for 2010. The December 31,2010,balance sheet of the calendar-year JKL Partnership reads as follows.     Each partner shares in 1/3 of the partnership capital,income,gain,loss,deduction and credit.On December 31,2010,Jan sells her 1/3 partnership interest to Jennifer for $43,000 cash.Assume the partnership makes a § 754 election for 2010.

(Essay)
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Which of the following statements about the transfer of a partnership interest is not true?

(Multiple Choice)
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Carl receives a proportionate nonliquidating distribution when the basis of his partnership interest is $60,000.The distribution consists of $20,000 in cash and property with an adjusted basis to the partnership of $35,000 and a fair market value of $40,000.Carl's basis in the noncash property and his remaining basis in the partnership interest are:

(Multiple Choice)
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Which of the following distributions would never result in gain recognition to the recipient partner?

(Multiple Choice)
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A partnership may make an optional election to adjust the basis of its property on a distribution to a partner which liquidates the partner's entire interest in the partnership.If such an election is in effect,the partnership:

(Multiple Choice)
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Nick sells his 25% interest in the LMNO Partnership to new partner Nancy for $50,000.The partnership's assets consist of cash ($100,000),land (basis of $60,000;fair market value of $40,000),and inventory (basis of $50,000;fair market value of $60,000).Nick's basis in his partnership interest was $52,500.On the sale,Nick will recognize ordinary income of $2,500 and a capital loss of $5,000.

(True/False)
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Tina sells her 1/3 interest in the TAX Partnership to James for $60,000 cash plus the assumption of Tina's $4,000 share of partnership debt.On the sale date,the partnership balance sheet and agreed-upon fair market values were as follows: Tina sells her 1/3 interest in the TAX Partnership to James for $60,000 cash plus the assumption of Tina's $4,000 share of partnership debt.On the sale date,the partnership balance sheet and agreed-upon fair market values were as follows:   As a result of the sale,Tina recognizes: As a result of the sale,Tina recognizes:

(Multiple Choice)
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Jamie owns a 40% interest in the JSD LLC.In liquidation of the entity,Jamie receives a proportionate distribution of $20,000 cash,inventory (basis of $12,000 and fair market value of $14,000),and land (basis of $10,000 and fair market value of $30,000).Jamie's basis in the entity immediately before the distribution was $50,000.As a result of the distribution,what is Jamie's basis in the inventory and land,and how much gain or loss does she recognize?

(Multiple Choice)
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