In Which of the Following Independent Situations Would the Transaction

question 112

Multiple Choice

In which of the following independent situations would the transaction most likely be characterized as a disguised sale?

• A)Partner George contributes appreciated property to the GMVV Partnership, and three years later GMVV distributes $100,000 proportionately to all the partners.
• B)Brianna contributes property with a basis of $20,000 and a fair market value of $50,000 to the BGB Partnership in exchange for a 20% interest therein.The partnership agrees to distribute $20,000 to Brianna in fifteen months, if partnership cash flows from operations exceed $100,000 at that time.The partnership does not expect to produce operating cash flows of over $100,000 for at least five years.
• C)Luis contributes appreciated property to the BLP Partnership.Thirty months later, he receives a distribution from the partnership of $15,000 cash.None of the other partners received a distribution.There was no agreement that BLP would make the distribution, and Luis would have made the contribution whether or not the partnership made the distribution.
• D)None of the above transactions will be treated as a disguised sale.
• E)a., b., and c.are all treated as disguised sales.

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Definitions:

Authoritative Precedent

A judicial decision that is binding on lower courts within the same jurisdiction, guiding future cases with similar issues.

Manitoba Court

The judicial system or a specific court within the province of Manitoba, Canada, handling legal matters within its jurisdiction.

Ontario Court of Appeal

The highest appellate court in the province of Ontario, Canada, responsible for reviewing decisions of lower courts.

Federal Court of Appeal

A court that reviews decisions made by lower courts, typically involving issues of national importance or federal law in a given country.