Problem -
A, B, C, and D are sole proprietors, each individually engaged in the business of free-lance court reporting. All four individuals report their income on the cash method. They decide to form an equal, cash method, general partnership with interests of $30,000 each.
A contributes:
- $20,000.
- A's personal note for $15,000 with a $10,000 value.
B contributes:
- Personal automobile. Value $10,000, adjusted basis $15,000, owned ten years.
- Stock in Speed Reporting, Inc. held two weeks. Value $10,000, adjusted basis $10,000.
- Real property used in B's business valued at $10,000, adjusted basis $7,000, holding period of five years.
C contributes:
- Xerox duplicator-collator held several years. Value $30,000, Original Cost $40,000, adjusted basis $10,000. Three years remaining useful life.
D contributes:
- $25,000 in § 453 installment obligations acquired three months ago from the sale of property held for three years. Value $20,000, adjusted basis $15,000.
- Accounts receivable from his sole proprietorship valued at $10,000.
Questions -
1) What gain or loss is recognized to each partner as a result of these contributions?
2) What is the tax basis of each partner's interest in the partnership?
3) What is the partnership's basis in each asset?
4) a. What is each partner's holding period for his partnership interest?
b. What is the partnership's holding period for its assets?