Assume that all partnership interests expressed as percentages are those percentages of both profits/losses and capital. Assume that all liabilities are recourse.

SWFT Comprehensive Vol 2020
43rd Edition
ISBN:9780357391723
Author:Maloney
Publisher:Maloney
Chapter21: Partnerships
Section: Chapter Questions
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Partnership(taxation)
Assume that all partnership interests
expressed as percentages are those
percentages of both
profits/losses and capital. Assume that all
liabilities are recourse.
a) Three individuals, C, D, and E, form CDE
LLC. CDE LLC does not "check the box" to
become a corporation and therefore is
treated as a partnership for tax purposes. C
contributes land,
AB 70 FMV 100 and cash of 20. D
contributes inventory (in the hands of both
D and CDE), AB 50
FMV 120. E contributes services. In
exchange, each partner receives a 1/3
interest in the LLC.
What are the consequences to all of the
parties?
(b) Same as (a) except that C's land is
subject to an assumable mortgage of 30
and has a FMV of
130
Transcribed Image Text:Partnership(taxation) Assume that all partnership interests expressed as percentages are those percentages of both profits/losses and capital. Assume that all liabilities are recourse. a) Three individuals, C, D, and E, form CDE LLC. CDE LLC does not "check the box" to become a corporation and therefore is treated as a partnership for tax purposes. C contributes land, AB 70 FMV 100 and cash of 20. D contributes inventory (in the hands of both D and CDE), AB 50 FMV 120. E contributes services. In exchange, each partner receives a 1/3 interest in the LLC. What are the consequences to all of the parties? (b) Same as (a) except that C's land is subject to an assumable mortgage of 30 and has a FMV of 130
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