Business Homework Solutions
Problem
#128051

Recognition of gain in liquidation of a partner's interest

The Dec. 31, 2006, balance sheet of the BCD General Partnership reads as follows.
                                             Basis                        FMV
Cash                                    $180,000                   $180,000
Receivables                                      0                              0
Capital assets                           42,000                       63,000
    Total                                 $222,000                   $333,000    

Ben, capital                             $74,000                   $111,000
Cassie, capital                           74,000                     111,000
Deidra, capital                           74,000                     111,000
   Total                                  $222,000                    $333,000

Each partner shares in 1/3 of the partnership capital, income, gain, loss, deduction and credit. Capital is not a material income-producing factor to the partnership. On Dec. 31, 2006, general partner Cassie receives a distribution of $120,000 cash in liquidation of her partnership interest under section 736. Nothing is stated in the partnership agreement about goodwill. Cassie's outside basis for the partnership interest immediately before the distribution is $74,000.

How much is Cassie's recognized gain from the distribution and what is the character of the gain?


Solution Summary

The solution explains the applicability of a tax code section to the liquidation of a partner's full interest in a partnership.  The gain is calculated and the reporting (where and how much) is discussed.

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