Gains recognized for significant experience
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Beth and Ben are equal partners in the BB partership, formed on June 1 of the current year. Ben contributed land that he inherited form his father 3 years ago. Ben's father purchased the land in 1950 for $6,000. The land was worth $50,000 when Ben's father died. The fair market value of the land was $75,000 at the date it was contributed to the partnership.
Beth has significant experience developing real estate. After the partnership is formed, she will prepare a plan for developing the property and secure zoning approvals for the partneship. She would normally bill a third party $25.000 for these efforts. Beth will also contribute %50,000 of cash in exchange for her 50% interest in the partnership. The value of her 50% interest is $75,000.
How much gain or income will Ben recognize on his contribution of the land to the partnership? What is the character of any gain or income recognized.
What bais will Ben take in his partnership interest?
How much gain or income will Beth recognize on the formation of the partnership? What is the character of any gain or income recognized.
What bais will Beth take in her partneship intestest?
Constuct an opening balance sheet for the partnership reflecting the partnership's basis in assets and the fair market value of these assets.
Outline any planning opportunities that may minimize current taxation to any of the parties.
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Gains recognized for significant experiences are examined.
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How much gain or income will Ben recognize on his contribution of the land to the partnership? What is the character of any gain or income recognized.
Section 712 of the Internal Revenue Code provides, in general, that no gain or loss is recognized when property is contributed to a partnership in exchange for a partnership interest.
What basis will Ben take in his partnership interest?
hence, Ben's basis in his partnership ...
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