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Old 07-21-2003, 12:50 AM
Mike Lewis
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Default Re: Not Making the 754 election

"david banford" <dban1957[at]aol.com> wrote:

- quote -

> I am curious on how most practitioners handle the problem on
> partnership returns when the inside basis does not equal the
> outside basis.
> For example, a partner dies and the estate values his
> partnership interest at $300,000 but his capital account is
> $500,000. The partnership does not make the 754 election.
> Question: Do practitioners create a dummy account (balance
> sheet item) on the partnership return for the $200,000
> difference ($500,000 capital account less the $300,000 FMV)
> Or do you leave the partnership books alone, making the
> successor's capital account $500,000 on the tax return, and
> keep track of the basis outside of the partnership.
> Any input on this would be greatly appreciated.


We set up the difference, even if negative, in a balance
sheet account with the balancing entry to capital. If all
or part of the asset is depreciable property, we show an
annual "depreciation" entry that we refer to as
non-deductible. Then we code our tax software in such a way
that the partner whose basis changed is the only one with a
"non-deductible" transaction.

Mike Lewis, CPA

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Old 07-18-2003, 07:24 PM
Dave Woods, EA
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Posts: n/a
Default Re: Not Making the 754 election

"david banford" <dban1957[at]aol.com> wrote:

- quote -

> I am curious on how most practitioners handle the problem on
> partnership returns when the inside basis does not equal the
> outside basis.
> For example, a partner dies and the estate values his
> partnership interest at $300,000 but his capital account is
> $500,000. The partnership does not make the 754 election.
> Question: Do practitioners create a dummy account (balance
> sheet item) on the partnership return for the $200,000
> difference ($500,000 capital account less the $300,000 FMV)
> Or do you leave the partnership books alone, making the
> successor's capital account $500,000 on the tax return, and
> keep track of the basis outside of the partnership.


If the partner's capital is greater than his value on a
change of ownership interest, I wouldn't do a thing and
track the basis separately from capital.

--
David M. Woods, EA
Boston, MA 02109

Postings here are general information only and not to be
relied upon as advice.

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #-1  
Old 07-17-2003, 02:07 PM
david banford
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Posts: n/a
Default Not Making the 754 election

I am curious on how most practitioners handle the problem on
partnership returns when the inside basis does not equal the
outside basis.

For example, a partner dies and the estate values his
partnership interest at $300,000 but his capital account is
$500,000. The partnership does not make the 754 election.

Question: Do practitioners create a dummy account (balance
sheet item) on the partnership return for the $200,000
difference ($500,000 capital account less the $300,000 FMV)

Or do you leave the partnership books alone, making the
successor's capital account $500,000 on the tax return, and
keep track of the basis outside of the partnership.

Any input on this would be greatly appreciated.

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
 

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