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Question
Samantha is a forty percent partner in Stevens LLC. Her tax basis in her partnership interest is $57,000. She received a non-liquidating distribution of real property (§1231 property to the partnership) with a fair market value of $100,000 and a tax basis of $65,000. Following the distribution, the partnership had remaining assets as follows:
Basis FMV
Cash $ 10,000 $ 10,000
Real Estate (§1231 Property):
Tract 1 54,000 70,000
Tract 2 65,000 45,000
Tract 3 71,000 95,000
$200,000 $220,000
i. Assume the LLC has a §754 election in effect. What will be the amount of the basis adjustment under §734(b)?
ii. How will the basis adjustment be allocated among the partnership's remaining properties?
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