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Linda pays $100,000 cash for Jerry’s ¼ interest in the JILL Partnership. The par

ID: 2476904 • Letter: L

Question

Linda pays $100,000 cash for Jerry’s ¼ interest in the JILL Partnership. The partnership has a Sec. 754 election effect. Just before the sale of Jerry’s interest, JILL’s balance sheet appears as follows:

Partnership’s Basis

FMV

Assets:

Cash

$75,000

$75,000

Land

$225,000

$325,000

Total

$300,000

$400,000

Partners' capital

Jerry

$75,000

$100,000

Instrument Corp

$75,000

$100,000

Logo Corp

$75,000

$100,000

Lighthouse Corp

$75,000

$100,000

Total

$300,000

$400,000

(If a partnership files an election, in accordance with regulations prescribed by the Secretary, the basis of partnership property shall be adjusted, in the case of a distribution of property, in the manner provided in section 734 and, in the case of a transfer of a partnership interest, in the manner provided in section 743. Such an election shall apply with respect to all distributions of property by the partnership and to all transfers of interests in the partnership during the taxable year with respect to which such election was filed and all subsequent taxable years. Such election may be revoked by the partnership, subject to such limitations as may be provided by regulations prescribed by the Secretary)

----If JILL parternship sells the land for its $325,000 FMV immediately after Linda purchases her interest, how much gain or loss will the partnership recognize?

----How much gain will Linda report as a result of the sale?

Partnership’s Basis

FMV

Assets:

Cash

$75,000

$75,000

Land

$225,000

$325,000

Total

$300,000

$400,000

Partners' capital

Jerry

$75,000

$100,000

Instrument Corp

$75,000

$100,000

Logo Corp

$75,000

$100,000

Lighthouse Corp

$75,000

$100,000

Total

$300,000

$400,000

Explanation / Answer

Linda pays $100,000 cash for Jerry’s ¼ interest in the JILL Partnership. The par

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