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Learning Objectives
- Learning Outcomes
- Calculate what a partner will receive in complete liquidation of their partnership interest under Section 704(b) regulations.
- Identify the potential economic consequences of special allocations to a partner or LLC member.
- Distinguish between “book” allocations required under Section 704(b) and “tax” allocations required under Section 704(c).
- Identify the potential tax consequences when a partner or LLC member makes a contribution of appreciated or depreciated property to the entity.
- Distinguish among the various methods prescribed by the regulations to make required special allocations with respect to contributed property.
- Distinguish between recourse and nonrecourse liabilities of a partnership or LLC.
- Calculate the basis of each property received by a partner or member receiving multiple properties in liquidating and nonliquidating distributions from a partnership or LLC.
- Recognize which properties will receive a step up or step down in basis when multiple properties are received from a partnership or LLC.
- Assess when a partnership or LLC should make a Section 754 election to allow it to increase or decrease the basis of its assets.
- Assess the consequences for the buyer associated with the sale of an interest in a partnership or LLC.
