Problem:
In each of the following situations, assume that capital accounts are maintained in accordance with the Sec. 704 regulations, the allocation is reflected in the capital account, and liquidation is in accordance with capital accounts with deficit balances to be restored on liquidation. Which of these special allocations has substantial economic effect? A. Partner A receives all depreciation deductions. Gains and losses from the sale of depreciable assets are allocated pro rata among the partners. B. Partner A is allocated all income (but not gain or loss) from $100,000 face amount 10% municipal bonds and Partner B is allocated all dividends (but not gain or loss) from $100,000 fair market value of G.M. stock. The interest and dividends are likely to be close to the same amount. C. Partner A is allocated 10% of all foreign source income of the partnership and all other partners receive the same dollar amount of U.S. source income. D. Partner A is allocated $10,000 of Sec. 1231 loss and all other partners are allocated $10,000 of depreciation deductions.