Gamila, James, Helen, and Carlos each own an equal interest in GJHC Partnership, a calendar-year-end, cash-method entity. On January 1 of the current
Gamila, James, Helen, and Carlos each own an equal interest in GJHC Partnership, a calendar-year-end, cash-method entity. On January 1 of the current year, James’ basis in his partnership interest is $62,000. For the taxable year, the partnership generates $80,000 of ordinary income and $30,000 of dividend income. For the first 5 months of the year, GJHC generates $25,000 of ordinary income and no dividend income. On June 1, James sells his partnership interest to Robert for a cash payment of $70,000. The partnership has the following assets and no liabilities at the sale date:
\r\nTax Basis FMV
\r\nCash $ 27,000 $ 27,000
\r\nLand held for investment 80,000 100,000
\r\nTotals $ 107,000 $ 127,000
\r\na. Assuming GJHC’s operating agreement provides that the proration method will be used to allocate income or loss when partners’ interests change during the year, what is James’ basis in his partnership interest on June 1 just prior to the sale?
\r\nb. What are the amount and character of James’s recognized gain or loss on the sale?
\r\nc. If GJHC uses an interim closing of the books, what are the amount and character of James’s recognized gain or loss on the sale?
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