Julie Is an Active Owner of a 52% Interest in the JIR

question 84

Essay

Julie is an active owner of a 52% interest in the JIR LLP, a consulting company service provider). Her basis in the partnership interest is $100,000, and her share of the partnership's inside basis in assets is $120,000. Julie can sell her interest in the LLP on the first day of the tax year to Irene and Rachel the other partners) for $100,000 each $200,000 total). Alternatively, the LLP can distribute $200,000 of cash to redeem Julie's interest.
Assume the following: $10,000 of the redemption payment would be for the LLP's goodwill which is not provided for in the partnership agreement); Julie's share of JIR's unrealized receivables is $40,000; and JIR has a § 754 election in effect. What are the advantages and disadvantages of the sale versus the redemption from Julie's and JIR's perspective? What is your recommendation? Explain.

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Definitions:

CAPM

The Capital Asset Pricing Model, a theory used in finance to determine a theoretically appropriate required rate of return of an asset, considering risk and the time value of money.

Asset Allocation

The strategy of distributing investments among different categories like stocks, bonds, and cash to reduce risk and increase the potential of return.

Excess Return

The return on an investment above the return on a risk-free investment or benchmark index.

Bogey Portfolio

A benchmark portfolio used to evaluate the performance of a mutual fund or investment manager, typically reflecting a standard or targeted investment strategy.