2.09.1 Partnership Operations and Partner's Taxable Income (7)

Question 問題、
Partnership LIFE's profits and losses are shared equally among the four partners. The adjusted basis of Partner E's interest in the partnership on December 31, Year 1, was $25,000. On January 2, Year 2, Partner E withdrew $10,000 cash. The partnership reported $200,000 as ordinary income on its Year 2 partnership return. In addition, $5,000 for qualified travel, meals, and entertainment was shown on a separate attachment to E's Schedule K-1 of Form 1065. Due to the limitation, $2,500 of the $5,000 is unallowable as a deduction. What is the amount of E's basis in the partnership on December 31, Year 2?

A. $60,000

B. $61,000

C. $65,000

D. $71,000

The correct answer is 正解は、[A. $60,000.]
= Basis $25,000 + (Income $200,000 /4) - Withdrew $10,000 - Expense $5,000
税務上控除できない項目についてもパートナーの持分は減算する。

2.09.1 Partnership Operations and Partner's Taxable Income (6)

Question 問題、
Jane and Bill are equal partners in J & B Partnership. The partnership incurred a $10,000 loss last year. Jane and Bill's adjusted basis in the partnership at the beginning of last year was $2,000 each. Under the partnership agreement, Jane and Bill share all partnership profits and losses equally. The partnership borrowed $20,000 last year to purchase depreciable equipment to be used in the partnership's business. Jane was required under the partnership agreement to pay the creditor if the partnership defaulted. Based upon these facts, what is Jane and Bill's allowable loss on last year's tax return?

A. Jane $2,000; Bill $2,000

B. Jane $5,000; Bill $2,000

C. Jane $5,000; Bill $5,000

D. Jane $10,000; Bill $0

The correct answer is 正解は、[B. Jane $5,000; Bill $2,000.]
借入$20,000に対し、パートナーシップ合意によりJaneのみが責任を負うので、Janeのbasisを$20,000増加させると、損失$10,000に対し、パス・スルー前の両者の持分はJane $22,000、Bill $2,000となる。
各パートナーが控除できる損失はパス・スルー直前の持分までなので、Billに割り当てられた損失のうち$3,000は翌年以降へ繰り越される。

2.09.1 Partnership Operations and Partner's Taxable Income (5)

Question 問題、
On January 1, 2016, Thomas contributed real estate he held for investment to Fog Partnership, a dealer in real estate. The real estate had an adjusted basis to Thomas of $50,000 and a fair market value at the time of the transfer of $43,000. On June 1, 2018, Fog sold the real estate for $40,000. What are the amount and the character of the partnership's loss?

A. $3,000 capital loss; $7,000 ordinary loss.

B. $7,000 capital loss; $3,000 ordinary loss.

C. $10,000 ordinary loss; $0 capital loss.

D. $10,000 capital loss; $0 ordinary loss.

The correct answer is 正解は、[B. $7,000 capital loss; $3,000 ordinary loss.]
現物拠出された資産を7年以内に分配または売却した場合、拠出時の含み損益を拠出したパートナーが認識しなければならない（Sec. 704 special allocation：特別配分規定）。
Basis $50,000 - FMV $43,000 = $7,000 Thomasにのみ割り当て (Thomasは投資資産として保有していたのでcapital loss）
FMV $43,000 - Sold $40,000 = $3,000 パートナー全員へ割り当て（ディーラーなのでordinary loss）

2.09.1 Partnership Operations and Partner's Taxable Income (4)

Question 問題、
Juan and Adelfo are equal partners in a music store. In 2018, they bought an amplifier for use in the store to demonstrate certain instruments. The amplifier cost $30,000. The partnership's taxable income before the Sec. 179 deduction is $25,000. What amount of Sec. 179 expense can Juan and Adelfo each deduct if neither has any other Sec. 179 deductions?

A. $0

B. $12,500

C. $30,000

D. $25,000

The correct answer is 正解は、[B. $12,500.]
= Taxable income $25,000 / 2 partners.
非関係者から購入した事業用の減価償却対象動産の取得価額は、取得年度にSec.179即費用化の選択により$1,020,000（2019年）まで即費用化できる。（選択年度に取得した動産の総額が$2,550,000（2019年）を超える場合には即費用化することができる金額が超えた$1につき$1削られる。）
なお、即費用化控除できる金額はその年度の事業活動からの課税所得が上限となる。
本問の場合、パートナーシップの事業活動からの課税所得$25,000が上限となる。（パートナーシップレベルでSec.179を適用する。）
Sec.179即費用化控除は個別記載項目となり、個別に各パートナーへパス・スルーされる。

2.09.1 Partnership Operations and Partner's Taxable Income (3)

Question 問題、
Comfy Chairs Manufacturing, Ltd. operates as a partnership and files Form 1065. Comfy manufactures inflatable lounge chairs. During the current tax year ended December 31, Comfy generated income and expenses as stated below. What is the correct amount of ordinary income (loss) from trade or business activities Comfy should report Schedule K for the current year?
- Employee wages $15,000
- Income from rental real estate $20,000
- Charitable contribution $500
- Cost of goods sold $10,000
- Income from chair sales $75,000

A. $65,000

B. $69,500

C. $50,000

D. $30,000

The correct answer is 正解は、[C. $50,000.]
= Sales $75,000 - COGS $10,000 - Wages $15,000
不動産賃貸所得、寄付金は個別記載項目なので、Ordinary Business Income/Lossには含めない。

2.09.1 Partnership Operations and Partner's Taxable Income (2)

Question 問題、
All of the following items must be separately stated on the partnership's Schedule K (Form 1065) and included as separate items on the partner's return EXCEPT

A. Ordinary gains and losses from Form 4797, Part II.

B. Gains and losses from sales or exchanges of capital assets.

C. Guaranteed payments to the partners.

D. Interest income.

The correct answer is 正解は、[A. Ordinary gains and losses from Form 4797, Part II.]
事業用資産の売却損益を計算するForm 4797 (Sales of Business Property) のうち、ordinary gain/lossは個別記載事項に含まれない。
(B) キャピタルゲイン/ロス、(C) パートナーへの保証支払額、(D) 利子所得は個別記載項目。

2.09.1 Partnership Operations and Partner's Taxable Income (1)

Question 問題、
Bridget and Brenda formed B & B Partnership in Year 1 as equal partners. They closed the business during Year 5 because it was not profitable. After the partnership closed, they had debts to pay. Because Bridget was insolvent, she paid only part of her share of the partnership's debts. Brenda was required to pay all of the remaining debts during Year 5. Which of the following statements reflects the correct treatment of the debts paid by Brenda on her tax return for Year 5?

A. She cannot deduct any of the debt she paid.

B. She can deduct only her payment of her share of the debt as a bad debt.

C. She can deduct all of the debt she paid as a bad debt.

D. She can deduct only her payment of Bridget's share of debt as a bad debt.

The correct answer is 正解は、[D. She can deduct only her payment of Bridget's share of debt as a bad debt.]
パートナーシップの負債に対し、パートナーが持分を超える返済を行った場合、超過部分は貸倒損失として控除できる。

2.08.4 Partnership Interest (2)

Question 問題、
Three individuals formed a partnership sharing in profits and losses equally.
Mr. Aardvark contributed $10,000 cash.
Mr. Baboon contributed $5,000 in cash and land worth $5,000 with an adjusted basis of $4,000.
Mr. Camel contributed machinery with a fair market value of $16,000 subject to a mortgage of $6,000, which the partnership assumed, and with an adjusted basis of $16,000.
The partnership has no other liabilities.
The adjusted basis of Mr. Baboon's interest in the partnership is

A. $5,000

B. $9,000

C. $10,000

D. $11,000

The correct answer is 正解は、[D. $11,000.]
= 現金 $5,000 + 土地（簿価） $4,000 + 引き受けた負債 $6,000 x 1/3

2.08.4 Partnership Interest (1)

Question 問題、
Ed and Bob form a partnership with contributions of $30,000 each. Bob is not a general partner. Under the partnership agreement, Ed and Bob share all partnership profits and losses equally. The partnership borrows $70,000 to purchase depreciable equipment to be used in the partnership's business. Only Ed was required under the partnership agreement to pay the creditor if the partnership defaulted.
Based upon these facts, what are Ed and Bob's basis in the partnership?

A. Ed $30,000; Bob $30,000.

B. Ed $65,000; Bob $65,000.

C. Ed $100,000; Bob $30,000.

D. Ed $100,000; Bob $100,000.

The correct answer is 正解は、[C. Ed $100,000, Bob $30,000.]
パートナーシップ合意によりEdのみが負債$70,000に対する責任を負うことになっているため、Edの持分を$70,000増加させる。

2.08.3 Contributions to a Partnership (4)

Question 問題、
Earl acquired a 20% interest in a partnership by contributing property that had an adjusted basis to him of $8,000 and that was subject to a mortgage of $12,000. Which of the following results is correct?

A. Capital Gain Recognized $1,600; Basis of Partnership interest $1,600.

B. Capital Gain Recognized $0; Basis of Partnership interest $(1,600).

C. Capital Gain Recognized $4,000; Basis of Partnership interest $8,000.

D. Capital Gain Recognized $1,600; Basis of Partnership interest $0.

The correct answer is 正解は、[D. Capital Gain Recognized $1,600, Basis of Partnership interest $0.]
負債の減少分$96,000 (= $12,000 x 80%) が、拠出した資産のbasis $8,000を超過しているため、差額$1,600についてgainを認識する。

2.08.3 Contributions to a Partnership (3)

Question 問題、
Jeffrey, the sole proprietor of a hardware business, hired Eastwood on January 1, Year 1, for an agreed salary and a promise to give him a 25% ownership interest if he were still employed at the end of 3 years, and an additional 25% interest if he continued in the business for a second 3-year period. On January 1, Year 4, a partnership was was formed and Eastwood received a 25% interest in the capital and profits of the business. On that date, the net worth of the partnership was $60,000. The partnership has no liabilities. What is Eastwood's tax basis of his partnership interest at January 1, Year 4, and what amount should be added to his gross income for Year 4?

A. Basis $0; Gross Income $0

B. Basis $15,000; Gross Income $15,000

C. Basis $30,000; Gross Income $15,000

D. Basis $30,000; Gross Income $30,000

The correct answer is 正解は、[B. Basis $15,000, Gross Income $15,000]
= $60,000 x 25%