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Cliff’s basis in his Aero Partnership interest is $18,500. Cliff receives a distribution of $24,100 cash from Aero in complete liquidation of his interest. Aero is an equal partnership with the following balance sheet: Tax Basis FMV Assets: Cash $ 24,100 $ 24,100 Investment 28,800 28,800 Land 2,600 36,700 Totals $ 55,500 $ 89,600 Liabilities and capital: Capital – Chris 18,500 – Cliff 18,500 – Cooper 18,500 Totals $ 55,500 a. If Aero has a §754 election in place, what is the amount of the special basis adjustment?

Question

Cliff’s basis in his Aero Partnership interest is 18,500.Cliffreceivesadistributionof18,500. Cliff receives a distribution of 24,100 cash from Aero in complete liquidation of his interest. Aero is an equal partnership with the following balance sheet:

 	Tax Basis	 	FMV

Assets: Cash 24,100 24,100 24,100 Investment 28,800 28,800 Land 2,600 36,700 Totals 55,500 55,500 89,600 Liabilities and capital: Capital – Chris 18,500 – Cliff 18,500 – Cooper 18,500 Totals $ 55,500

a. If Aero has a §754 election in place, what is the amount of the special basis adjustment?

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Solution

To calculate the special basis adjustment under §754 election, we need to follow these steps:

  1. Determine the amount realized by Cliff. In this case, Cliff received a distribution of 24,100cashincompleteliquidationofhisinterest.So,theamountrealizedis24,100 cash in complete liquidation of his interest. So, the amount realized is 24,100.

  2. Determine Cliff's basis in his partnership interest. According to the information given, Cliff's basis in his Aero Partnership interest is $18,500.

  3. Calculate the difference between the amount realized and Cliff's basis. This is the gain or loss realized by Cliff. In this case, 24,100(amountrealized)24,100 (amount realized) - 18,500 (Cliff's basis) = $5,600. This is a gain realized by Cliff.

  4. Determine the partnership's basis in the assets distributed to Cliff. According to the balance sheet, the tax basis of the assets is $55,500.

  5. Calculate the special basis adjustment. Under §754 election, the special basis adjustment is the difference between the partnership's basis in the assets distributed and the partner's basis in his partnership interest. In this case, 55,500(partnershipsbasisintheassets)55,500 (partnership's basis in the assets) - 18,500 (Cliff's basis in his partnership interest) = $37,000.

So, if Aero has a §754 election in place, the amount of the special basis adjustment is $37,000.

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