Jack and Jill formed a limited partnership. Jack contributed $90,000 in exchange for a limited interest and Jill contributed $10,000 in exchange for…

1.    Jack and Jill formed a limited partnership. Jack contributed $90,000 in exchange for a limited interest and Jill contributed $10,000 in exchange for a general partnership interest. The partnership agreement provides that capital accounts are to be maintained in accordance with the regulations, that Jill has an obligation to restore a negative capital account, and that liquidating distributions would be made in accordance with capital account balances. With respect to Jack, the partnership agreement has a qualified income offset. The partnership agreement also contains a minimum gain chargeback provision. The agreement provides that any excess nonrecourse debt (i.e., third tier) be allocated equally between the partners. Finally, the partnership agreement allocates all items of income, loss, and deduction (including depreciation, but not including nonrecourse deductions) 90 percent to Jack and 10 percent to Jill and allocates all nonrecourse deductions 80 percent to Jack and 20 percent to Jill, until the first time the partnership recognizes items of income and gain that exceed the items of loss and deduction it had recognized over its life. Then, all further income, loss, and deduction items are to be allocated equally between Jack and Jill.

The partnership purchased a building for $300,000, using the $100,000 cash contributed by the partners and financing the remaining $200,000 with a nonrecourse debt, secured by the building. No payments are due on the loan for five years. Ignoring all conventions, in each year the partnership is entitled to $50,000 of depreciation. In each year, before taking into consideration the depreciation, partnership income is equal to its expenses.

a.    What is each partner’s outside basis and capital account at the end of the first year?

b.    What is each partner’s outside basis and capital account at the end of the second year?

c.    What is each partner’s outside basis and capital account at the end of the third year?

2.    Sean and Pat formed a general partnership to which Sean contributed $50,000 of cash and Pat contributed depreciable property with fair market value of $50,000 and a basis of $20,000. The property has a ten-year cost recovery period, of which 5 years are remaining on the contribution date; it is being depreciated under the straight-line method. The partnership agreement provides that Sean and Pat will share profits and losses equally. Each year the partnership recognizes $12,000 of gross income and no deductions other than the depreciation deductions on the contributed property.

a.    Assume the partnership applies the traditional method of making section 704(c) allocations.

i.              How much depreciation will be allocated to Sean and Pat, respectively, for book and tax purposes in year 1?

ii.             At the end of year 5, what are Sean and Pat’s tax and book capital accounts? (Be sure to take the $12,000 annual partnership gross income into account.)

b.    Assume alternatively the partnership applies the remedial method of making section 704(c) allocations.

i.              What are Sean and Pat’s tax and book capital accounts at the end of year 1?

ii.             What are Sean and Pat’s tax and book capital accounts at the end of year 6?

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