Question details

A and B form the AB partnership on January 1, 2015. A contributes real property
$ 10.00

A and B form the AB partnership on January 1, 2015. A contributes real property (10 year straight-line recovery property) she has held for many years with a basis of $500,000 and fair market value of $1,000,000 in exchange for her partnership interest and while B contributes $250,000 in cash in exchange for her partnership interest. A and B have agreed to share profits and losses from the partnership equally but that AB shall allocate 90% of all depreciation deductions from the real property to A. AB partnership elects a December 31 tax year and AB had the following income and expenses during its calendar tax year which ended December 31 of the current year:       

Gross Receipts inventory sales

550,000

COGS

(35000)

Salaries to Non partners

(15000)

Depreciation

(50000)

Advertising

(15000)

 

  • 1Create AB partnership’s balance sheet as of formation on January 1, 2015 in including partners’ basis and capital accounts.
  • 2Assuming all special allocations have economic effect, how and when will AB, and A and B report the income and who will be liable for the taxes?
  • 3What the tax consequences to A and B from the first year of operation?
  • 4Summarize the regulatory requirements which AB must satisfy in order for the allocation of depreciation to have economic effect.
  • 5How would your answer change, if at all, in (b) and (c) if it was determined that the allocation of depreciation to A lacked substantial economic effect. Explain your answer.
  • 6Assume  the facts of (b) and (c), if in 2016 AB’s non separately stated income equals  its expenses (not including separately stated depreciation) except that AB sells  the real estate for $1,000,000 what are the tax consequences to AB, A and B?  Explain you answer.
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