Essay
Anne contributes property to the TCA Partnership, which was formed eight years ago by Clark and Tara. Anne's basis for the property is $90,000 and the fair market value is $220,000. Anne receives a 25% interest for her contribution. Because the TCA Partnership is unsuccessful in having the property rezoned from agricultural to commercial, it sells the property 14 months later for $225,000.
a. Anne has no recognized gain under § 721 and a carryover basis for
her partnership interest of $90,000. The partnership has a
a. Determine the tax consequences to Anne and to the partnership on the contribution of the property to the partnership.
b. Determine the tax consequences to Anne and the other partners on the sale of the property.
b. differ if the entity were an S corporation?
c. Would the tax consequences in
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