Free sex cam chat with strange girls - Define nonliquidating assets

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The partnership uses $60 of its cash to purchase nondepreciable Blackacre, and after Blackacre has increased in value to $340, cash of $120 is distributed to P in a nonliquidating distribution.

After the distribution, the books of the partnership read (where “CA” stands for capital account and “OB” stands for outside basis): If the partnership has an election under §754 in effect, it is entitled to an inside basis increase of $20;[12] such an adjustment will equalize aggregate inside basis (now $80, $20 in the remaining cash and $60 in Blackacre) with aggregate outside basis (now $100, all in Q’s outside basis).

Because aggregate inside basis and aggregate outside basis each represent the after-tax (and debt financed) investment in partnership assets, they should equal one another.[4] They start equal by reason of the basis rules applicable to contributions of property (including the debt allocation rules of section 752),[5] and they will in general remain equal throughout the life of the partnership.[6] The examples presented throughout this Article do not consider the case of partnership indebtedness, although adding debt to the transaction should not change the analysis.

When they are not equal, astute taxpayers can exploit the difference.[7] Suppose, for example, that aggregate outside basis is higher than aggregate inside basis.

Because while the amount of the section 734(b) adjustment is computed properly,[10] the allocation of that adjustment is not right.

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