Two years ago, Tom contributed investment land with a basis of $50,000 and an FMV of $62,000 to the RST Partnership. This year, Tom has a basis in his partnership interest of $53,000 when he receives a current distribution of $14,000 cash and inventory with a basis of $35,000 and an FMV of $52,000. (There is no Sec. 751 exchange in connection with the inventory distribution.) The partnership

continues to hold the land Tom contributed. How much gain (if any) must Tom recognize as a result of this distribution?

What will be an ideal response?


Precontribution gain = $62,000 - $50,000 = $12,000

Predistribution basis $53,000
Minus: cash distribution ( 14,000)
$39,000

Minus: FMV of distribution other than cash ( 52,000)
Tentative Sec. 737 gain $13,000

Recognized gain = $12,000 [the smaller of precontribution gain ($12,000) or tentative Sec. 737 gain ($13,000)].

Business

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