Individual - closed partnership with $203,000 ending capital. I did not do the 1065. Withdrew bare land. Then did 1031 exchange for 4 rentals. Question - his starting basis for the exchange is the $203,000?
TaxConnections Members... Answer This Question Want To be One of Our Tax Experts? Register Here
Tax Professional Answers
Assuming that the land was a capital or 1231 asset; that it was the only property distributed; and that section 751 does not apply to the distribution...then generally the land would take a basis equal to your partner's outside basis in his partnership interest immediately before the distribution. There are situations in which a partner's outside basis is different than his or her share of capital. So, a partner's capital account is not always a surrogate for his or her outside basis. For example, if a partner purchased the partnership interest and the partnership did not have a valid 754 election to increase the purchasing partner's basis in partnership assets. After determining the partner's basis in the land, then you would go through your 1031 analysis to determine the basis in the property received.Leave a Comment 304 weeks ago