Читать книгу Taxation Essentials of LLCs and Partnerships - Larry Tunnell - Страница 26

Jamie contributed property with a tax basis of $28,000 and a fair-market value of $50,000 to the JQL partnership in exchange for a one-third interest therein. She will recognize no gain or loss on exchange of the property for the partnership interest. Her basis in her partnership interest is $28,000, and the partnership takes a $28,000 basis in the property contributed by Jamie. Assuming that Jamie subsequently decides to sell her interest in the partnership for its $50,000 value, she will recognize a taxable gain of $22,000. This is the same amount of gain she would have recognized had she sold the property rather than contributing it to the partnership. Likewise, if the partnership sells the property contributed by Jamie for its $50,000 fair market value, it will also recognize a $22,000 gain. Therefore, transfer of the property to the partnership does not change the tax consequences associated with a later sale of the property or of the partnership interest received in exchange for the property.