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James and Kendis Created the JK Partnership by Contributing $60,000

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Essay

James and Kendis created the JK Partnership by contributing $60,000 each. The $120,000 cash was used by the partnership to acquire a depreciable asset. The partnership agreement provides that the partners' capital accounts will be maintained in accordance with Reg. § 1.704-1(b) (the "economic effect" Regulations) and that any partner with a deficit capital account will be required to restore that capital account when the partner's interest is liquidated. The partnership agreement provides that MACRS will be allocated 10% to James and 90% to Kendis. All other items of partnership income, gain, loss, deduction, and credit will be allocated equally between the partners. In the first year, MACRS is $20,000 and no other operating transactions occur. The property is sold at the end of the year for $100,000 and the partnership is liquidated immediately thereafter.
To satisfy the economic effect test, how much of the $100,000 cash (from the sale) is allocated each to James and Kendis?

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Definitions:

Cardiovascular Disease

A class of diseases that involve the heart or blood vessels, including coronary artery disease, hypertension, and heart failure.

Educational Level

The highest degree or level of school completed, which often influences employment opportunities, income level, and health outcomes.

Behavioral Risk Factors

Actions or behaviors that increase the likelihood of developing diseases or health problems, such as smoking or a sedentary lifestyle.

Cardiovascular Disease

Denotes a group of conditions affecting the heart or blood vessels, including issues like coronary artery disease and stroke.

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