Nupartner purchases a one-third interest in the following three-person equal partnership for $40,000. At the time of the purchase the partnership has the following assets:
A.B. F.M.V.
Accounts Receivable $0 $30,000
Land (capital asset) 60,000 90,000
The partnership has made no Internal Revenue Code Section 754 election. It immediately distributes $10,000 of receivables to each of the three partners.
(a) What result to Nupartner on the collection of the receivables if Nupartner makes no Internal Revenue Code Section 732(d) election?
(b) What result to Nupartner on the collection of the receivables if he makes an Internal Revenue Code Section 732(d) election?
(c) If Nupartner elects Internal Revenue Code Section 732(d), what is his outside basis immediately after the distribution?
(d) Must the partnership approve Nupartner’s election under Internal Revenue Code Section 732(d)?
(e) Will the Internal Revenue Code Section 732(d) election have any immediate effect on the basis of Nupartner’s interest in the land remaining in the partnership?