A, B, and C form the equal ABC partnership by contributing the following real properties, all of which are held as an investment by both the partners and the partnership:
Partner Property A.B. F.M.V.
A #1 $2,000 $10,000
B #2 5,000 10,000
C #3 10,000 10,000
Assume that ABC uses the “traditional method” of allocation under Tax Regulation Section 1.704-3(b). What are the tax consequences to the partners in the following transactions, assuming the partners’ outside basis and ABC’s inside basis in the land are unchanged at the time of each transaction, if the ABC partnership:
(a) Sells property #1 for $10,000.
(b) Distributes property #1 to C six years after formation of the partnership.
(c) Distributes property #3 to A six years after formation of the partnership.
(d) Distributes property #2 to A six years after formation of the partnership.
(e) Distributes property #2 to A one year after formation of the partnership.
(f) Simultaneously distributes property #1 to B and property #2 to A six years after formation of the partnership and the properties are like kind properties.
(g) Distributes property that is like kind to property #1 to A six years after formation of the partnership.