The Oswego Lumber LLP is equally owned by two partners and shows the following balance sheet at the end of the current tax year. BasisFMV Cash$1,200,000$1,200,000 Unrealized receivables01,800,000 Long-term securities2,500,0002,700,000 Land2,700,0006,500,000 $6,400,000$12,200,000 Blue, capital$3,200,000$6,100,000 Ben, capital3,200,0006,100,000 $6,400,000$12,200,000 Partner Blue is an active (i.e., “general”) partner retiring from the service-oriented partnership. He receives $6,800,000 cash, none of which is stated to be for goodwill.
a. How much of the payment is for “unstated goodwill?” The distribution results in “unstated goodwill” of $.
b. How is the $6,800,000 allocated between a § 736
(a) income payment and a § 736
(b) property payment?
The $6,800,000 cash payment is allocated as follows: § 736
(a) income payment: $………………………..? § 736
(b) property payment:………………………
