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

ID: 2337481 • Letter: H

Question

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

For this question and question number 10 only, assume that instead of a liquidation of Honeymooner or a redemption of Kramden’s interest, Kramden sells his entire partnership interest to Alice for $80,000; what gain or loss does Kramden recognize and what is the character of such gain or loss assuming that the purchase price was allocated based on the above values under arm’s length negotiations?

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

As per question, Since it is considered that Kramden has sold his entire partnership share to Alice for $80000, There will be No gain/loss to Kramden, as per below calculations:

Kramden's Adjusted basis in Partneship =Total Fair market value. of partnsrhip assets*Share in partnership

= 160000*50%

= 80000

Gain/Loss = sale price of partneship interest - Adjusted basis in partneship

= 80000-80000

= 0