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Lori, a partner in the JKL partnership, received a proportionate current nonliquidating) distribution of $10,000 cash, unrealized receivables with a basis of $0 and a fair market value of $15,000, and land with a basis of $6,000 and a fair market value of $10,000. Her basis in the partnership interest immediately before the distributions was $14,000. She will recognize $0 gain on the distribution, and her basis in the receivables and land will be $0 and $4,000, respectively.

A) True
B) False

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Carl's basis in his LLC interest is $10,000. In a current nonliquidating) distribution, Carl receives land basis = $10,000; fair market value = $12,000); and inventory basis = $6,000; fair market value = $8,000). Carl takes a $10,000 basis in the land and a $0 basis in the inventory, and has a $0 basis in the LLC interest.

A) True
B) False

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Nicky's basis in her partnership interest was $150,000, including her $40,000 share of partnership liabilities. The partnership decides to liquidate, and after repaying all liabilities, distributes all remaining assets proportionately to the partners. Nicky receives $30,000 cash and inventory with a $50,000 basis and a $58,000 fair market value to the partnership. What loss does Nicky recognize, and what is her basis in the inventory?


A) $70,000 loss; $50,000 basis.
B) $30,000 loss; $50,000 basis.
C) $22,000 loss; $58,000 basis.
D) $62,000 loss; $58,000 basis.
E) $0 loss; $80,000 basis.

F) B) and E)
G) D) and E)

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Zach's partnership interest basis is $100,000. Zach receives a proportionate, liquidating distribution from a liquidating partnership of $50,000 cash and inventory having a basis of $20,000 to the partnership and a fair market value of $30,000. Zach assigns a basis of $20,000 to the inventory and recognizes a $30,000 loss.

A) True
B) False

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Match the following statements with the best match from the following choices. Choice K may be used more than once. -Nonqualified distribution


A) Cash basis accounts receivable, for example.
B) Fair market value exceeds 120% of basis.
C) Inside basis of partnership property can be adjusted to reflect the purchase price paid.
D) Terminates the partner's interest in the partnership.
E) Ordinary income-producing items.
F) Cash, then inventory and unrealized receivables, and then other assets.
G) Does not eliminate the partner's interest in the partnership.
H) Changes the partner's or the partnership's ordinary income potential.
I) Any partnership assets other than cash, capital, or § 1231 assets.
J) Sometimes treated as an unrealized receivable.
K) No correct match provided.

L) A) and J)
M) C) and E)

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Which of the following statements, if any, about a multimember LLC is false?


A) A multimember LLC is usually taxed like a partnership.
B) Members of an LLC generally have limited personal liability for debts of the LLC except for the managing member who has unlimited liability for LLC debts.
C) Members of an LLC can participate in management of the LLC unless the member agrees not to participate.
D) An LLC can specially allocate income items as long as the substantial economic effect rules of § 704b) are followed.
E) All of these are true.

F) None of the above
G) B) and E)

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On August 31 of the current tax year, the balance sheet of the RBD General Partnership reads as follows  Adjusted  Basis  FMV  Cash $150,000$150,000 Receivables 090,000 Capital assets 600,000660,000 Total $750,000$900,000 Nonrecourse debt $150,000$150,000 Rachel, capital 200,000250,000 Barry, capital 200,000250,000 Dale, capital 200,000250,000 Total $750,000$900,000\begin{array} { l r r } & \text { Adjusted } \\& \text { Basis } & \text { FMV } \\\text { Cash } & \$ 150,000 & \$ 150,000 \\\text { Receivables } & -0- & 90,000 \\\text { Capital assets } & \underline{600,000} & \underline{660,000} \\\text { Total } & \$ 750,000 & \$ 900,000\\\\\text { Nonrecourse debt } & \$ 150,000 & \$ 150,000 \\\text { Rachel, capital } & 200,000 & 250,000 \\\text { Barry, capital } & 200,000 & 250,000 \\\text { Dale, capital } & \underline{200,000} & \underline{250,000} \\\text { Total } & \$ 750,000 & \$ 900,000\end{array} On that date, Rachel sells her one-third partnership interest to Lisa for $300,000, consisting of cash and relief of Rachel's share of the nonrecourse debt. The nonrecourse debt is shared equally among the partners. Rachel's outside basis for her partnership interest is $250,000 including her share of partnership debt). How much capital gain and/or ordinary income will Rachel recognize on the sale?

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Rachel's realized gain is $50,000 $300,0...

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A cash distribution from a partnership to a partner generally is taxable to the partner.

A) True
B) False

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Matt, a partner in the MB Partnership, receives a proportionate, current nonliquidating) distribution of property having a fair market value of $16,000 and a partnership basis of $23,000. Matt's basis in the partnership is $10,000 before the distribution. In this situation, Matt will recognize no gain or loss. He takes a $10,000 basis in the property, and his basis in the partnership interest is reduced to zero.

A) True
B) False

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Which of the following statements is true regarding the sale of a partnership interest?


A) The selling partner's share of partnership liabilities is disregarded in determining the proceeds from the sale of a partnership interest.
B) For purposes of computing the selling partner's gain or loss, the partner's basis in the partnership interest is determined as of the last day of the partnership tax year ending before the year in which the interest is sold.
C) If a partner sells an interest in a partnership, income related to that interest for the year of the sale is allocated to the purchaser.
D) The selling partner could be required to report both ordinary income and a capital gain or loss on sale of the partnership interest.
E) The partner's share of partnership "hot assets" is disregarded in determining the character of the partner's gain on the sale of the partnership interest.

F) A) and B)
G) None of the above

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D

Match the following statements with the best match from the following choices. Choice M may be used more than once. -General partner


A) Includes the partner's share of partnership liabilities.
B) Could result from sale of a partnership interest for more than the partner's share of the inside basis of assets.
C) Liquidation payments from this type of partnership are always § 736b) payments.
D) Could arise if a distribution results in loss to the distributee partner.
E) May be a § 736a) payment.
F) May receive § 736a) payments.
G) Probably treated as a general partner for § 736 purposes
H) Conversion of an LLC to a C corporation
I) Liquidation payments from this type of partnership may include § 736a) payments.
J) A § 736b) payment.
K) Adjustment designed to bring inside and outside bases into balance.
L) Partnership asset basis is at least $250,000 > FMV.
M) No correct match is provided.

N) F) and L)
O) D) and M)

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F

Match the following independent descriptions as hot i.e., ordinary income-producing) or nonhot assets with the following statements. -Marketable securities not held as inventory) .


A) Hot assets for purposes of distributions, liquidation of a partnership interest under § 736, and sale of a partnership interest.
B) May be a hot asset for some but not all the purposes stated in a) .
C) Not a hot asset.

D) A) and C)
E) A) and B)

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On December 31 of last year, Maria gave her daughter, Chelsea, a gift of a 25% interest in a partnership in which capital is a material income-producing factor. For the current calendar year, the partnership's ordinary income was $100,000. Maria and Chelsea were the only partners, and there were no guaranteed payments. Maria's services performed for the partnership were worth $60,000, and Chelsea has never performed any services. What is Maria's distributive share of partnership income for the current year?


A) $25,000
B) $60,000
C) $75,000
D) $90,000
E) $100,000

F) D) and E)
G) B) and C)

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In a proportionate liquidating distribution of his 40% interest in the RST LLC, Stuart received cash $100,000), land basis of $60,000 and value of $90,000), and inventory basis of $30,000 and value of $40,000). In addition, Stuart is relieved of his $80,000 share of the LLC's liabilities. Stuart's basis in RST including his share of LLC liabilities) was $200,000 immediately prior to this distribution. a. How much gain or loss does Stuart recognize on this distribution? b. What is Stuart's basis in the land and inventory he receives in the distribution?

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a. Stuart recognizes no gain or loss. He received a cash distribution of $180,000 including his relief of liabilities), which did not exceed his basis of $200,000. b. Stuart's basis is reduced to $20,000 by the cash distribution. The inventory is distributed next. He has a substituted basis in the inventory of $20,000, and the partnership interest basis is reduced to $0.Therefore, the land takes a $0 basis.

The BLM LLC's balance sheet on August 31 reads as follows.  Adjusted  Basis  FMV  Cash $60,000$60,000 Receivables 0150,000 Capital assets 90,000300,000$150,000$510,000 Nonrecourse debt $90,000$90,000 Barney, capital 20,000140,000 Lillie, capital 20,000140,000 Marshall, capital 20,000140,000$150,000$510,000\begin{array}{lrr}&\text { Adjusted } & \\&\text { Basis } & \text { FMV } \\\text { Cash } & \$ 60,000 & \$ 60,000 \\\text { Receivables } & -0- & 150,000 \\\text { Capital assets } & \underline{90,000} & \underline{300,000} \\& \$ 150,000 & \$ 510,000\\\\\text { Nonrecourse debt } & \$ 90,000 & \$ 90,000 \\\text { Barney, capital } & 20,000 & 140,000 \\\text { Lillie, capital } & 20,000 & 140,000 \\\text { Marshall, capital } &{20,000}& \underline{140,000} \\&{\$ 150,000} & \$ 510,000\end{array} The nonrecourse debt is shared equally among the LLC members. On that date, Lillie sells her one-third interest to Robyn for $170,000, including cash and relief of Lillie's share of the nonrecourse debt. Lillie's outside basis for her interest in the LLC is $50,000, including her share of the LLC's debt. How much capital gain and/or ordinary income will Lillie recognize on the sale?


A) $100,000 capital gain? $50,000 ordinary income.
B) $120,000 capital gain? $0 ordinary income.
C) $150,000 capital gain? $0 ordinary income.
D) $150,000 capital gain? $50,000 ordinary income
E) $70,000 capital gain? $50,000 ordinary income.

F) All of the above
G) C) and D)

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Match the following statements with the best match from the following choices. Choice M may be used more than once. -Mandatory step down


A) Includes the partner's share of partnership liabilities.
B) Could result from sale of a partnership interest for more than the partner's share of the inside basis of assets.
C) Liquidation payments from this type of partnership are always § 736b) payments.
D) Could arise if a distribution results in loss to the distributee partner.
E) May be a § 736a) payment.
F) May receive § 736a) payments.
G) Probably treated as a general partner for § 736 purposes
H) Conversion of an LLC to a C corporation
I) Liquidation payments from this type of partnership may include § 736a) payments.
J) A § 736b) payment.
K) Adjustment designed to bring inside and outside bases into balance.
L) Partnership asset basis is at least $250,000 > FMV.
M) No correct match is provided.

N) G) and J)
O) H) and I)

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In a proportionate liquidating distribution in which the partnership is also liquidated, Ralph received cash of $30,000, accounts receivable basis of $0, fair market value of $20,000), and land basis of $1,000, fair market value of $10,000; treated as a capital asset by the partnership). Immediately before the distribution, Ralph's basis in the partnership interest was $40,000. Ralph realizes and recognizes a loss of $9,000, and his basis is $0 in the accounts receivable and $1,000 in the land.

A) True
B) False

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In a proportionate current nonliquidating) distribution, cash is deemed to be distributed first followed by capital and § 1231 assets, and last, unrealized receivables and inventory.

A) True
B) False

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In the year that a donor gives a partnership interest to a donee, their share of the partnership's income is prorated between the donor and donee.

A) True
B) False

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Jeremy sold his 40% interest in the HIJ Partnership to Ashley for $400,000. The inside basis of all partnership assets was $600,000 at the time of the sale. If the partnership makes a § 754 election, it will record a $160,000 step-up in the basis of the partnership assets, and the step-up will be attributed solely to Ashley.

A) True
B) False

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