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1 Honeymooner is a calendar year general partnership whose partners, Kramden and

ID: 2337482 • Letter: 1

Question

1

Honeymooner is a calendar year general partnership whose partners, Kramden and Norton, share equally in the profits, losses and capital. Kramden and Norton founded the partnership several years ago and funded the partnership with cash contributions. As of December 31, 2003, the partnership had the following balance sheet:

Description

Tax Basis

Fair Market Value

Cash

$30,000

$30,000

Inventory

$10,000

$50,000

Equipment

$20,000

$70,000

Land Held for Investment

$120,000

$10,000

Totals

$180,000

$160,000

Capital

Kramden

$90,000

$80,000

Norton

$90,000

$80,000

Totals

$180,000

$160,000

The partnership is liquidated by the following distributions:

Description

Tax Basis

Fair Market Value

To Kramden: Cash

$30,000

$30,000

Inventory

$10,000

$50,000

Totals

$40,000

$80,000

To Norton Equipment:

$20,000

$70,000

Land

$120,000

$10,000

Totals

$140,000

$80,000

0) What is Alice’s tax basis in her partnership interest and if Honeymooner has an IRC Section 754 election in effect, what basis adjustments must Honeymooner make on the sale of the interest from Kramden to Alice and to what assets are such adjustments allocated?

Description

Tax Basis

Fair Market Value

Cash

$30,000

$30,000

Inventory

$10,000

$50,000

Equipment

$20,000

$70,000

Land Held for Investment

$120,000

$10,000

Totals

$180,000

$160,000

Capital

Kramden

$90,000

$80,000

Norton

$90,000

$80,000

Totals

$180,000

$160,000

Explanation / Answer

ANSWER:

Here the given distributions were current distribution,

Distribution of assests Kramden Norton Cash $ 30000 Inventory $ 10000 Equipment $ 20000 Land $ 120000 Total 30000+10000= $ 40000 20000+120000= $ 140000 Capital Account $ 90000 $ 90000 Gain / Loss $ 50000 $ 80000