] Marco, Jaclyn, and Carrie formed Daxing Partnership (a calendar-year-end entity) by contributing cash 10 years ago. Each partner owns an equal inter
] Marco, Jaclyn, and Carrie formed Daxing Partnership (a calendar-year-end entity) by contributing cash 10 years ago. Each partner owns an equal interest in the partnership and has an outside basis in their partnership interest of $104,000. On January 1 of the current year, Marco sells his partnership interest to Ryan for a cash payment of $137,000. The partnership has the following assets and no liabilities as of the sale date:
\r\nTax Basis Fair Market Value
\r\nCash $ 18,000 $ 18,000
\r\nAccounts receivable -0- 12,000
\r\nInventory 69,000 81,000
\r\nEquipment 180,000 225,000
\r\nStock investment 45,000 75,000
\r\nTotals $ 312,000 $ 411,000
\r\nThe equipment was purchased for $240,000, and the partnership has taken $60,000 of depreciation. The stock was purchased seven years ago.
\r\na. What are the hot assets [§751(a)] for this sale?
\r\nb. What is Marco’s gain or loss on the sale of his partnership interest?
\r\nc. What is the character of Marco’s gain or loss?
\r\nd. What are Ryan’s inside and outside bases in the partnership on the date of the sale?
\r\n