Palmer Contributes Property with a Fair Market Value of $4,000,000

question 2

Essay

Palmer contributes property with a fair market value of $4,000,000 and an adjusted basis of $3,000,000 to AP Partnership. Palmer shares in $1,000,000 of partnership debt under the liability sharing rules, giving him an initial adjusted basis for his partnership interest of $4,000,000. One month after the contribution, Palmer receives a cash distribution from the partnership of $2,000,000. Palmer would not have contributed the property if the partnership had not contractually obligated itself to make the distribution. Assume Palmer's share of partnership liabilities will not change as a result of this distribution.
a. Under the IRS's likely treatment of this transaction, what is the amount of gain or loss that Palmer will recognize because of the $2,000,000 cash distribution?
b. What is the partnership's basis for the property after the distribution?
c. If Palmer is unhappy with this result, can you suggest a possible alternative that may provide him with a better answer?

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Definitions:

Hypokinesia

Reduced ability or slowness in movement, often seen in neurological conditions like Parkinson's disease.

Lesioning

The process of intentionally causing damage to body tissue, often in the brain, as a means of studying the functions of different regions.

Caudate Nucleus

A region of the brain within the basal ganglia, playing roles in various functions like movement control and learning processes.

Deep Brain Stimulation

A neurosurgical procedure involving the implantation of a medical device called a brain stimulator, which sends electrical impulses to specific targets in the brain for the treatment of movement and neuropsychiatric disorders.