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Old 02-28-2005, 06:57 PM
David Woods, EA, ChFC, CLU
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Default Re: Partnership Basis Question.

"LSarrett[at]gmail.com" <LSarrett[at]gmail.com> wrote:

- quote -

> Limited Partnership is formed with 2 LP's and a GP. GP puts
> in 1%, LP's put in remaining 99%. They purchase a piece of
> property which will be subdivided and sold off. The deal is
> that proceeds are allocated in ratio to the capital
> contributed up to the level that the all partners receive
> 100% of their initial contribution. After that the GP gets
> 30% and the remaining LP's split the 70%. Say original
> purchase price is $100k. They sell the 1/4 of the property
> for $100K in year one. They are each paid their initial
> contribution and profits are reported as $75k allocated by
> the original contribution percentage.
> As the remaining property is sold in future years, the
> proceeds are split 30/70 as indicated above. This results
> in the GP having negative basis (and the GP reports the
> appropriate capital gains for cash received in excess of
> basis). When the last piece of the property is sold, the
> LP's will still have positive capital accounts. Am I
> correct that at this time the LP's will be permitted to take
> the capital loss?


Sorry. You lost me when you stated the GP had a negative
basis after being allocated a much greater that
proportionate ownership share of income.

--
David M. Woods, EA, ChFC, CLU
Woods Financial Services
Norwood, MA 02062
www.woods-financial.com

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Old 02-28-2005, 06:19 PM
Thomas Healy
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Default Re: Partnership Basis Question.

"LSarrett[at]gmail.com" <LSarrett[at]gmail.com> wrote:

- quote -

> Limited Partnership is formed with 2 LP's and a GP. GP puts
> in 1%, LP's put in remaining 99%. They purchase a piece of
> property which will be subdivided and sold off. The deal is
> that proceeds are allocated in ratio to the capital
> contributed up to the level that the all partners receive
> 100% of their initial contribution. After that the GP gets
> 30% and the remaining LP's split the 70%. Say original
> purchase price is $100k. They sell the 1/4 of the property
> for $100K in year one. They are each paid their initial
> contribution and profits are reported as $75k allocated by
> the original contribution percentage.
> As the remaining property is sold in future years, the
> proceeds are split 30/70 as indicated above. This results
> in the GP having negative basis (and the GP reports the
> appropriate capital gains for cash received in excess of
> basis). When the last piece of the property is sold, the
> LP's will still have positive capital accounts. Am I
> correct that at this time the LP's will be permitted to take
> the capital loss?


Yes. I do wonder, though, why the extra payment to the GP
isn't handled as a Guaranteed Payment for services. That
would keep the profit allocations in line with capital
accounts, and the LP's wouldn't be stuck with a capital loss
down the road that could take many years to soak up at
$3,000 per year.

--
Tom Healy, CPA
Boulder, CO
Web: http://www.tomhealycpa.com

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  #-1  
Old 02-27-2005, 02:12 PM
LSarrett@gmail.com
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Posts: n/a
Default Partnership Basis Question.

Limited Partnership is formed with 2 LP's and a GP. GP puts
in 1%, LP's put in remaining 99%. They purchase a piece of
property which will be subdivided and sold off. The deal is
that proceeds are allocated in ratio to the capital
contributed up to the level that the all partners receive
100% of their initial contribution. After that the GP gets
30% and the remaining LP's split the 70%. Say original
purchase price is $100k. They sell the 1/4 of the property
for $100K in year one. They are each paid their initial
contribution and profits are reported as $75k allocated by
the original contribution percentage.

As the remaining property is sold in future years, the
proceeds are split 30/70 as indicated above. This results
in the GP having negative basis (and the GP reports the
appropriate capital gains for cash received in excess of
basis). When the last piece of the property is sold, the
LP's will still have positive capital accounts. Am I
correct that at this time the LP's will be permitted to take
the capital loss?

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

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