Jeremy Is an Active Partner Who Owns a 30% Interest

question 102

Essay

Jeremy is an active partner who owns a 30% interest in the JS LLP (in which capital is not a material income-producing factor). Partnership assets consist of land (fair market value of $200,000, basis of $140,000), accounts receivable (fair market value of $200,000, basis of $0), and cash of $400,000. JS distributes $220,000 of the cash to Jeremy in liquidation of his interest. In addition, Jeremy is relieved of his $40,000 share of the LLP's liabilities. The total payment includes $20,000 for Jeremy's share of JS goodwill (for which the agreement does not provide). Jeremy's basis in the partnership interest (including his share of the partnership's liabilities) is $120,000 immediately before the distribution. How much gain or loss does Jeremy recognize and what is its character? How much can the partnership deduct?

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Definitions:

Delayed Development Indicator

A sign or measure that suggests a slower than typical progress in physical, emotional, or intellectual growth in children.

Intellectual Disability

A condition characterized by significant limitations in intellectual functioning and in adaptive behavior, which covers a range of everyday social and practical skills.

Moderate

Not extreme or excessive; average in amount, intensity, quality, or degree.