11. George and James are forming the GJ Partnership. George contributes $600.000
ID: 2558417 • Letter: 1
Question
11. George and James are forming the GJ Partnership. George contributes $600.000 cash and James contributes land with an adjusted basis of $400,000 and a fair market value of S The property is subject to a $150,000 liability, which is is shared 60% by Geo 60% and 40% also transferred into the partnership and rge and 40% by James for basis purposes. George and James also share o respectively in all partnership profits except for any pre-contribution gain, whiclh must be allocated according to the statutory rules for built-in gain allocations. a. What is James's adjusted tax basis for his partnership interest immediately after the partnership is formed? b. What is the partnership's adjusted basis for the property contributed by James? If the partnership sells the property contributed by James for $800,000, how is the tax gain allocated between the partners? c.Explanation / Answer
a. James Adjusted tax basis: Adjusted basis of Land contributed 400000 Add:James share in property liability (150000*40%) 60000 460000 Less:Property liabilty transferred by James 150000 James Adjusted tax basis 310000 b. partnership’s adjusted basis for the property contributed by James=Adjusted basis of Land=$400000 c. Sales price 800000 Less: Adjusted basis 400000 Tax gain on sale 400000 Allocation of Tax gain: James George Pre-contribution gain (750000-400000) 350000 Remaining gain 50000 @ 40:60 20000 30000 Allocated tax gain 370000 30000
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