Show:
FORMATION
OPERATIONS
LOSSES
SPECIAL ALLOCATIONS
DISTRIBUTIONS
100
The general rule of §721.
What is no gain or loss is recognized to a partnership or a partner on a contribution of property in exchange for a partnership interest?
100
The election necessary to adjust the basis of partnership assets under §734(b) or §743(b).
What is a §754 election?
100
The three hurdles to deductibility of losses by a partner.
What are outside basis, at-risk amount & passive loss rules?
100
Name of the initial Tax Court case that set forth the principle that a special allocation has to have "Substantial Economic Effect."
What is Orrisch v. Commissioner?
100
Definition of an operating or current distribution.
What is any distribution that is not a liquidating distribution?
200
What a partner is entitled to upon liquidations of the parntership
What is a partner's capital account?
200
The two categories of "hot" assets under §751.
What are Inventory & Unrealized Receivables?
200
What happens to losses that is disallowed.
What is they are suspended are carried forward?
200
The three prongs of the primary test for Economic Effect.
What are (1) capital accounts must be maintained in accordance with regulations, (2) liquidating distributions must be made in accordance with positive capital accounts and (3) partnership agreement must contain a deficit restoration obligation?
200
The general rule of section 731(a).
What is partner does not recognize gain on a distribution from the partnership?
300
The tax consequence of a capital interest received subject to the performance of future services.
What is - it is not taxable under §83 until the restrictions lapse (unless an election is made under §83(b))?
300
The reason why some items of partnership income or loss are separately stated when reported on a partner's schedule K-1
What is because there is potentially varying tax consequences to different partners?
300
The exception to the rule that only amounts borrowed, for which the partner is personally liable, are included in amount at-risk.
What is Qualified Nonrecourse Financing?
300
How often you check for substantial economic effect.
What is every year that a special allocation exists?
300
The category of the asset which, when distributed, results in ordinary income to the recipient-partner, if sold within five years of distribution.
What is inventory?
400
The two principles of §752.
What is an increase in a partner's share of liabilities is treated as a cash contribution (increases outside basis) and a decrease in a partner's share of liabilities is treated as cash distribution (decreases outside basis)?
400
The three categories of payments made by a partnership to a partner.
What is (1) a payment which is part of distributive share of income, (2) a payment for services rendered or for the use of property, made to the partner in a capacity other than as partner, or (3) a guaranteed payment?
400
The four components of a partner's amount at risk in an activity.
What are (1) cash contributions, (2) adjusted basis of other property contributed, (3) amounts borrowed for use in the activity for which taxpayer is personally liabile, (4) partner's share of income/loss & distributions?
400
When the economic effect of an allocation is not substantial.
What is the after-tax economic consequence of one partner improves while no other partner suffers an economic detriment (government is only loser)?
400
The type of asset whose basis can be increased or decreased in a liquidating distribution.
What is a capital or 1231 asset?
500
The motive necessary to convert mere co-ownerhship into a separate entity.
What is joint profit motive?
500
The three primary reasons why a partner's outside basis is important?
What is it (1) determines a partner's gain on the sale of her partnership interest; (2) determines when distributions become taxable; and (3) provides a limit on the deductibility of losses?
500
If you fail this test, your involvement in an activity is passive.
What is material particpation?
500
Two types of allocations that will automatically be considered insubstantial.
What are shifting allocations and transitory allocations?
500
Three possible choices for taxing a withdrawal payment/ distribution to a partner under §736.
What is as (1) a distribution, (2) distributive share of partnership income, and (3) guaranteed payment?