Bryan and Cody each contributed $120,000 to the newly formed BC Partnership in exchange for a 50% interest. The partnership used the available funds to acquire equipment costing $200,000 and to fund current operating expenses. The partnership agreement provides that depreciation will be allocated 80% to Bryan and 20% to Cody. All other items of income and loss will be allocated equally between the partners. Upon liquidation of the partnership, property will be distributed to the partners in accordance with their § 704(b) book capital account balances. Any partner with a negative capital account must contribute cash in the amount of the negative balance to restore the capital account to $0. In its first year, the partnership reported an ordinary loss (before depreciation) of $80,000 and depreciation expense of $36,000. In its second year, the partnership reported $40,000 of income from operations (before depreciation), and it reported depreciation expense of $57,600. a. Calculate the partners' bases in their partnership interests at the end of the first and second tax years.

SWFT Comprehensive Volume 2019
42nd Edition
ISBN:9780357233306
Author:Maloney
Publisher:Maloney
Chapter21: Partnerships
Section: Chapter Questions
Problem 57P
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Bryan and Cody each contributed $120,000 to the newly formed BC Partnership in exchange for a 50% interest. The partnership used the
available funds to acquire equipment costing $200,000 and to fund current operating expenses. The partnership agreement provides that
depreciation will be allocated 80% to Bryan and 20% to Cody. All other items of income and loss will be allocated equally between the
partners.
Upon liquidation of the partnership, property will be distributed to the partners in accordance with their § 704(b) book capital account
balances. Any partner with a negative capital account must contribute cash in the amount of the negative balance to restore the capital
account to $0.
In its first year, the partnership reported an ordinary loss (before depreciation) of $80,000 and depreciation expense of $36,000. In its
second year, the partnership reported $40,000 of income from operations (before depreciation), and it reported depreciation expense of
$57,600.
a. Calculate the partners' bases in their partnership interests at the end of the first and second tax years.
Bryan's Basis
Cody's Basis
Capital contribution-Year 1
Loss allocation-Year 1
Depreciation allocation-Year 1
Basis at the end of Year 1
Income allocation-Year 2
Depreciation allocation-Year 2
Basis at the end of Year 2
sa va a cabeza a ca
$
$
$
120,000 ✓
40,000
28,800 ✓
51,200 ✓
20,000 ✓
46,080 ✓
25,120
✓
120,000 ✓
40,000
7,200 ✔
72,800
✓
20,000 ✓
11,520 ✓
81,280
✓
Transcribed Image Text:Bryan and Cody each contributed $120,000 to the newly formed BC Partnership in exchange for a 50% interest. The partnership used the available funds to acquire equipment costing $200,000 and to fund current operating expenses. The partnership agreement provides that depreciation will be allocated 80% to Bryan and 20% to Cody. All other items of income and loss will be allocated equally between the partners. Upon liquidation of the partnership, property will be distributed to the partners in accordance with their § 704(b) book capital account balances. Any partner with a negative capital account must contribute cash in the amount of the negative balance to restore the capital account to $0. In its first year, the partnership reported an ordinary loss (before depreciation) of $80,000 and depreciation expense of $36,000. In its second year, the partnership reported $40,000 of income from operations (before depreciation), and it reported depreciation expense of $57,600. a. Calculate the partners' bases in their partnership interests at the end of the first and second tax years. Bryan's Basis Cody's Basis Capital contribution-Year 1 Loss allocation-Year 1 Depreciation allocation-Year 1 Basis at the end of Year 1 Income allocation-Year 2 Depreciation allocation-Year 2 Basis at the end of Year 2 sa va a cabeza a ca $ $ $ 120,000 ✓ 40,000 28,800 ✓ 51,200 ✓ 20,000 ✓ 46,080 ✓ 25,120 ✓ 120,000 ✓ 40,000 7,200 ✔ 72,800 ✓ 20,000 ✓ 11,520 ✓ 81,280 ✓
b. Does the allocation provided in the partnership agreement have an "economic effect"?
, because (1) gains, income, loss, and other allocations are
distributions are in accordance with ending
Yes
reflected in capital account balances; (2) liquidating
capital account balances; and (3) deficit capital accounts
must be restored.
c. Now assume that on the first day of the third tax year, the partnership sells the equipment for $150,000. The gain on the sale is
allocated equally to the partners. The partnership distributes all cash in accordance with the partners' capital account balances, and the
partnership liquidates. How will partnership cash balances be distributed to the partners upon liquidation? (Hint: First, calculate the
partners' bases in their partnership interests after reflecting any gain or loss on disposal of the equipment. Disregard any depreciation in
year 3.) What observations can you make regarding the value of a deduction to each partner?
The realized gain
on the sale of the equipment is $
The partners' bases in their partnership interests after reflecting any gain or loss on disposal of the equipment: Bryan's basis is
, and Cody's basis is
What observations can you make regarding the value of a deduction to each partner?
Bryan will receive $
46,920 of the sales proceeds.
Cody will receive $
103,080 of the sales proceeds.
Bryan has directly reduced
his right to cash flows on liquidation in favor of current deductions from taxable income
Absent the special allocation of depreciation, the parties each would have received $
on the distribution of sale proceeds.
Therefore, the economic effect rules ensure that a deduction reflects a true economic consequence
to the partner.
Transcribed Image Text:b. Does the allocation provided in the partnership agreement have an "economic effect"? , because (1) gains, income, loss, and other allocations are distributions are in accordance with ending Yes reflected in capital account balances; (2) liquidating capital account balances; and (3) deficit capital accounts must be restored. c. Now assume that on the first day of the third tax year, the partnership sells the equipment for $150,000. The gain on the sale is allocated equally to the partners. The partnership distributes all cash in accordance with the partners' capital account balances, and the partnership liquidates. How will partnership cash balances be distributed to the partners upon liquidation? (Hint: First, calculate the partners' bases in their partnership interests after reflecting any gain or loss on disposal of the equipment. Disregard any depreciation in year 3.) What observations can you make regarding the value of a deduction to each partner? The realized gain on the sale of the equipment is $ The partners' bases in their partnership interests after reflecting any gain or loss on disposal of the equipment: Bryan's basis is , and Cody's basis is What observations can you make regarding the value of a deduction to each partner? Bryan will receive $ 46,920 of the sales proceeds. Cody will receive $ 103,080 of the sales proceeds. Bryan has directly reduced his right to cash flows on liquidation in favor of current deductions from taxable income Absent the special allocation of depreciation, the parties each would have received $ on the distribution of sale proceeds. Therefore, the economic effect rules ensure that a deduction reflects a true economic consequence to the partner.
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