Hard1 markMultiple Choice
Area 4: Entity TaxationEntity TaxationPartnerships

CPA · Question 53 · Area 4: Entity Taxation

Partner Z sells their 30% interest in a partnership for ,000 cash. Z's outside basis was ,000. The partnership has no liabilities but has 'Hot Assets' (Unrealized Receivables) of ,000. What is the character of Z's gain?

Answer options:

A.

,000 Capital Gain

B.

,000 Ordinary Income; ,000 Capital Gain

C.

,000 Ordinary Income

D.

,000 Ordinary Income; ,000 Capital Gain

How to approach this question

1. Calculate Total Gain. 2. Calculate Share of Hot Assets (Inventory/Receivables). 3. Hot Asset Share = Ordinary Income. 4. Remainder = Capital Gain.

Full Answer

B.,000 Ordinary Income; ,000 Capital Gain✓ Correct
,000 Ordinary Income; ,000 Capital Gain
Under Section 751, the amount of money received attributable to unrealized receivables or substantially appreciated inventory ('Hot Assets') results in ordinary income. Z's share of receivables is ,000 (30% * ,000). Total gain is ,000. ,000 is ordinary, ,000 is capital.

Common mistakes

Treating the entire sale of partnership interest as capital gain.

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