Tax Assignment 3

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Assignment 3

1. Yvonne and Larry plan to begin a business that will grow plants for sale to retail

nurseries. They expect to have substantial losses for the first three years of operations while

they develop their plants and their sales operations. Both Yvonne and Larry have

substantial interest income, and both expect to work full-time in this new business. List

three advantages for operating this business as a partnership instead of a C corporation.

Advantages include

(1) partnerships are not subject to tax, thereby eliminating the problem of double taxation that

exists for C corporations,

(2) partners may divide the partnership's profit or loss among themselves without regard to their

proportionate capital interests,

(3) under the conduit principle of taxation, partnership losses and other items receiving special

tax treatment flow through to the partners.

2. Which of the following items can be deducted (up to $5,000) and amortized as part of a

partnership's organizational expenditures?

A. Legal fees for drawing up the partnership agreement

B. Accounting fees for establishing an accounting system

D. Filing fees required under state law in the initial year to conduct business in the state
3. The BW Partnership reported the following current-year earnings: $30,000 interest from

tax exempt bonds, $50,000 long-term capital gain, and $100,000 net income from

operations. Bob saw these numbers and told his partner, Wendy, that the partnership had

$100,000 of taxable income. Is he correct? Explain your answer.

Bob is incorrect; the ordinary income for BW is $100,000. The total taxable income for BW

would be $150,000 (100,000+50,000).

4. Can recourse debt of a partnership increase the basis of a limited partner's partnership

interest? Explain

No, because a limited partner normally has no economic risk for recourse debt.

5. Roy's father gives him a capital interest in the Family Partnership. Discuss whether Sec.

704€ family partnership rules apply to this interest.

The Sec. 704(e) rules apply only to a capital interest in a partnership, where capital is a material

income-producing factor and where the family member is the true owner of the interest. If capital

is a material income-producing factor for the partnership, the family partnership rules apply.

6. Why did Congress enact the 20% qualified business income deduction?

A tax rate somewhat comparable to the 21% corporate tax rate. Thus, Congress did not want to

give a tax break to C corporations while not giving a tax break to businesses operating in a pass-

through form.

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