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A contributes $100,000 cash to the AB partnership and B contributes a building w

ID: 2574881 • Letter: A

Question

A contributes $100,000 cash to the AB partnership and B contributes a building with an adjusted basis of $50,000 and a fair market value of $100,000. Unless otherwise stated, apply the traditional method with respect to all contributed property.

NEED HELP ON E, F & G.

(a) If the building is depreciable, has a 10-year remaining recovery period and is depreciated under the straight-line method, how much tax and book depreciation will be allocated to each partner?

(c) Same as (a), above, except that B’s basis in building is $40,000?

(e) If in (a), above, the building is sold for $90,000 after it has been held (and depreciated) by the partnership for two years, how must the partnership allocate the tax gain on the sale?

(f) Same as (e), above except the building is sold for $60,000?

(g) What result in (c), above, if the recovery period for the building is 20 years and the partnership elects the remedial method of allocation?

Explanation / Answer

Answer -

A. Traditional Method

Partner A is Non-contributing partner whereas partner B is Contributing partner.

Tax Depreciation on Building for one year for the Partnership = $ 50,000/10 = $ 5,000

Book Depreciation on building for one year for the Partnership = $ 1,00,000/10 = $ 10,000

Allocation of Book Depreciation to Partner A = $ 5,000

Allocation of book Depreciation to Partner B = $ 5,000

Allocation of Tax Depreciation to Partner A = $ 5,000

Allocation of Tax Depreciation to Partner B = $ 0

As per the traditional method, Book Depreciation is allocated to partners both Contributing and Non- Contributing partners.

Tax depreciation is allocated to Non contributing partners upto the book depreciation amount, if any tax depreciation remains after that, it is allocated to contributing partner.

______________________________________________________________________________________

E. Bulding sold for 90,000 after depreciation for 2 years

book value of building after 2 years = Book value - book depreciation = 1,00,000 - (2*10,000) = $ 80,000

tax basis of building after 2 years = Tax basis - tax deprciation = 50,000 - (2*5,000) = $ 40,000

Book gain = 90,000 - 80,000 = 10,000

Tax gain = 90,000 - 40,000 = 50,000

A

B

Tax Basis

Capital Account

Tax Basis

Capital Account

80,000

80,000

40,000

80,000

Book Gain ( $ 10,000)

0

5,000

0

5,000

Tax gain ( $ 50,000)

0

0

50,000

0

Totals

80,000

85,000

80,000

85,000

_______________________________________________________________________________________

F. Bulding sold for 60,000 after depreciation for 2 years

book value of building after 2 years = Book value - book depreciation = 1,00,000 - (2*10,000) = $ 80,000

tax basis of building after 2 years = Tax basis - tax deprciation = 50,000 - (2*5,000) = $ 40,000

Book loss = 80,000 - 60,000 = 20,000

Tax gain = 60,000 - 40,000 = 20,000

Therefore at a gain/ loss of $ 10,000 will be created for remedial allocation

A

B

Tax Basis

Capital Account

Tax Basis

Capital Account

80,000

80,000

40,000

80,000

Book loss ( $ 20,000)

0

-10,000

0

-10,000

Tax gain ( $ 20,000)

0

0

20,000

0

created gain/loss

-10000

10,000

Totals

70,000

70,000

70,000

70,000

__________________________________________________________________________________________

G. under Remedial method

Partner B contributes building with FMV as $ 1,00,000 and Tax basis as $ 40,000

the built in gain of building = $ 1,00,000 - $ 40,000 = $ 60,000

Book depreciation = Tax basis / 20 = 40,000/20 = $ 2,000

Tax Depreciation = built in gain/ 20 = 60,000/20 = $ 3,000

Allocation of Book depreciation to PArtner A = $ 2,500 ($ 2,000 * 0.5 + $ 3,000 * 0.5)

Allocation of Book Depreciation to PArtner B = $ 2,500 ($ 2,000 * 0.5 + $ 3,000 * 0.5)

Allocation of Tax Depreciation to PArtner A = $ 2,000

Allocation of Tax Depreciation to PArtner B = $ 0

Remedial Allocation to PArtner A = $ 500

Remedial Allocation to PArtner B = - $ 500

___________________________________________________________________________________________

A

B

Tax Basis

Capital Account

Tax Basis

Capital Account

80,000

80,000

40,000

80,000

Book Gain ( $ 10,000)

0

5,000

0

5,000

Tax gain ( $ 50,000)

0

0

50,000

0

Totals

80,000

85,000

80,000

85,000

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