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Carrie DLake, Reed A. Green, and Doug A. Divot share a passion for golf and decide to go into the golf club manufacturing business together. On January 2, 2022, DLake, Green, and Divot form the Slicenhook Partnership, a general partnership. Slicenhooks main product will be a perimeter-weighted titanium driver with a patented graphite shaft. All three partners plan to actively participate in the business. The partners contribute the following property to form Slicenhook:

Partner	Contribution
Carrie DLake	Land, FMV	$ 468,000
	Basis $468,000, Mortgage	$ 68,000
Reed A. Green	Cash	$ 400,000
Doug A. Divot	Cash	$ 400,000

Carrie had recently acquired the land with the idea that she would contribute it to the newly formed partnership. The partners agree to share in profits and losses equally. Slicenhook elects a calendar year-end and the accrual method of accounting. In addition, Slicenhook received a $1,596,000 recourse loan from Big Bank at the time the contributions were made. Slicenhook uses the proceeds from the loan and the cash contributions to build a state-of-the-art manufacturing facility ($1,240,000), purchase equipment ($624,000), and produce inventory ($416,000). With the remaining cash, Slicenhook invests $53,000 in the stock of a privately owned graphite research company and retains $63,000 as working cash. Slicenhook operates on a just-in-time inventory system so it sells all inventory and collects all sales immediately. That means that at the end of the year, Slicenhook does not carry any inventory or accounts receivable balances. During 2022, Slicenhook has the following operating results:

Sales		$ 1,158,000
Cost of goods sold		416,880
Interest income from tax-exempt bonds		980
Qualified dividend income from stock		1,740
Operating expenses		134,000
Depreciation (tax)
179 on equipment	$ 39,000
Equipment	89,000
Building	32,000	160,000
Interest expense on debt		200,000

The partnership is very successful in its first year. The success allows Slicenhook to use excess cash from operations to purchase $39,000 of tax-exempt bonds (you can see the interest income already reflected in the operating results). The partnership also makes a principal payment on its loan from Big Bank in the amount of $300,000 and a distribution of $100,000 to each of the partners on December 31, 2022. The partnership continues its success in 2023 with the following operating results:

Sales		$ 1,572,000
Cost of goods sold		550,550
Interest income from tax-exempt bonds		980
Qualified dividend income from stock		1,740
Operating expenses		148,000
Depreciation (tax)
Equipment	$ 163,000
Building	70,000	233,000
Interest expense on debt		112,000

The operating expenses include a $2,200 trucking fine that one of its drivers incurred for reckless driving and speeding and meals expense of $6,000 (the meals were not provided by a restaurant). By the end of 2023, Reed has had a falling out with Carrie and Doug and has decided to leave the partnership. He has located a potential buyer for his partnership interest, Indie Ruff. Indie has agreed to purchase Reeds interest in Slicenhook for $858,000 in cash and the assumption of Reeds share of Slicenhooks debt. Carrie and Doug, however, are not certain that admitting Indie to the partnership is such a good idea. They want to consider having Slicenhook liquidate Reeds interest on January 1, 2024. As of January 1, 2024, Slicenhook has the following assets:

	Tax Basis	FMV
Cash	$ 892,800	$ 892,800
Investmenttax exempts	39,000	34,000
Investment stock	85,000	85,000
Equipmentnet of depreciation	349,000	624,000
Buildingnet of depreciation	1,178,000	1,600,000
Land	500,000	590,000
Total	$ 3,043,800	$ 3,825,800

Carrie and Doug propose that Slicenhook distribute the following to Reed in complete liquidation of his partnership interest:

	Tax Basis	FMV
Cash	$ 493,000	$ 493,000
Investment stock	85,000	85,000
Equipment$200,000 cost, net of depreciation	112,600	280,000
Total	$ 690,600	$ 858,000

Slicenhook has not purchased or sold any equipment since its original purchase just after formation.

h-1. If Reed sells his interest in Slicenhook to Indie Ruff, what is Indie's inside basis in Slicenhook?

h-2. What effect would a 754 election have on Indies inside basis?

i-1. If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reeds partnership interest, what are the amount and character of Reeds recognized gain or loss?

i-2. If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reeds partnership interest, what is Reeds basis in the distributed assets? Cash basis? Investment in stock basis? Equipment basis?

j-1. If Reed sells his interest, what is his after-tax cash? Assume his ordinary marginal tax rate is 35 percent and his capital gains tax rate is 15 percent.

j-2. If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reed's partnership interest and Reed were to immediately sell the distributed assets, what is his after-tax cash? Assume his marginal tax rate is 35 percent and his capital gains rate is 15 percent.

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