Anne decides to leave the ABC Partnership after owning the interest for many years. She owns a 52% capital, profits, and loss interest in the general partnership (which is not a service partnership). Anne's basis in her partnership interest is $ 120,000 just before she leaves the partnership. The partnership agreement does not mention payments to partners who leave the partnership. The partnership has not made an optional basis adjustment election ( Sec. 754). All partnership liabilities are recourse liabilities, and Anne's share is equal to her loss interest. When Anne leaves the partnership, the assets and liabilities for the partnership are as follows:
Assets Partnership's Basis FMV
Cash $240,000 $240,000
Inventory 24,000 24,000
Receivables 0 64,000
Land 60,000 100,000
Total $324,000 $428,000
Liablities 60,000 60,000
Analyze the following two alternatives, and answer the associated problems for each alternative.
a. Anne could receive a cash payment of $ 220,000 from the partnership to terminate her interest in the partnership. Does Anne or the partnership have any income, deduction, gain, or loss? Determine both the amount and character of any items.
b. Carrie already owns a 30% general interest in the ABC partnership prior to Anne's departure. Carrie is willing to buy Anne's partnership interest for a cash payment of $ 220,000. What income, gain, loss, or deduction will Anne recognize on the sale? What are the tax implications for the partnership if Carrie buys Anne's interest?