Problem
Vincent is a 50% partner in the TAV Partnership. He became a partner three years ago when he contributed land with a value of $60,000 and a basis of $30,000 (current value is $100,000). Tyler and Anita each contributed $30,000 cash for a 25% interest. Vincent's basis in his partnership interest is currently $135,000; the other partners' bases are each $82,500. The partnership holds the following assets.
|
|
Basis
|
FMV
|
|
Cash
|
$200,000
|
$200,000
|
|
Accounts receivable
|
-0-
|
200,000
|
|
Marketable Securities
|
70,000
|
100,000
|
|
Land
|
30,000
|
100,000
|
|
Total
|
$300,000
|
$600,000
|
A. In general terms (i.e., no calculations are required), describe the tax results to the partners and the partnership in each of the following independent scenarios where the partnership distributes the assets indicated in a current nonliquidating distribution at the end of its tax year. Hint: You should first determine whether the distributions are proportionate.
a. TAV distributes a $50,000 (FMV) plot of land each to Tyler and Anita and $100,000 of accounts receivable to Vincent.
b. TAV distributes $100,000 of cash to Vincent, $50,000 (FMV) of marketable securities to Tyler, and $50,000 (FMV) of accounts receivable to Anita.
c. TAV distributes a $50,000 (FMV) interest in the land and $50,000 (FMV) of accounts receivable to Vincent and $25,000 of cash and $25,000 (FMV) of accounts receivable each to Anita and Tyler.
B. Now consider what would happen if the partnership distributed all of its assets in a liquidating distribution. In deciding the allocation of assets, what issues should the partnership consider to minimize each partner's taxable gains?