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Question - Essay - Property contributions and special allocations under Section 704(c) -
a) What is built-in gain on contributed property? What tax basis does the partnership take when property with built-in gain is contributed to the partnership? What do tax rules require when property with built-in gain is sold or depreciated and why does the tax law impose these requirements. Provide an example of each.
b) What is built-in loss on contributed property? What tax basis does the partnership take when property with built-in loss is contributed to the partnership? What do tax rules require when property with built-in loss is sold or depreciated. Provide an example of each.
c) Answer the questions below.
1) Explain the traditional method of special tax allocations and provide an example. How does the ceiling rule limit the effectiveness of the traditional method?
2) Explain the traditional method with curative allocations and provide an example.
3) Explain the remedial method, contrast it with the traditional method, and provide an example.
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