In a Proportionate Current (Nonliquidating) Distribution of His 30% Interest

question 228

Essay

In a proportionate current (nonliquidating) distribution of his 30% interest in the MNO LLC, Neil received cash
($60,000), land (basis of $40,000 and value of $75,000), and unrealized receivables (basis of $0 and value of
$22,000). In addition, Neil is relieved of his $40,000 share of the LLC's liabilities. Neil's basis in MNO (including his share of LLC liabilities) was $80,000 immediately prior to this distribution.

a. How much gain or loss does Neil recognize on this distribution?
b. What is Neil's basis in the receivables and land he receives in the distribution?
c. What is Neil's basis in the LLC interest following the distribution?

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Definitions:

Stock Dividends

A form of dividend payment made by a corporation to its shareholders in the form of additional shares, rather than cash.

Factors of Production

The inputs used in the production of goods or services; traditionally includes land, labor, capital, and entrepreneurship.

Marginal Product

The additional output a firm gains from employing one more unit of input, holding the levels of all other inputs constant.

Marginal Product

The increase in output that arises from an additional unit of input, holding all other inputs constant.