Add 1231 gain to partner's outside basis?

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  • Tom in Seattle
    Junior Member
    • Apr 2011
    • 4

    #1

    Add 1231 gain to partner's outside basis?

    Partnership sold real estate with slightly more than enough cash to pay off its debt. Partnership then terminated.

    Taxpayer/partner's final K-1 reports net section 1231 gain of $100. This gain arose mainly from the allocation to the partner of a deferred gain (arising from a 1031 exchange). (A portion of the gain is section 1250 gain, so also adding that into outside basis would be double counting).
    Partner's share of debt paid off was $12.
    $10 net rental loss (box 2).
    $3 of cash was distributed to the partner and reported in Box 19. No other distributions are on the final K-1.

    My main concerns are
    A) is the 1231 gain is added into the outside basis?
    B) will the final outside basis then be written off as a capital loss, (thereby offsetting to offset the 1231 gain reported on the final K-1)? If not, where have I gone off-track?

    Outside basis calculation:
    Note: Beginning outside basis is not the beginning capital account on the K-1.

    Outside basis - year end beginning of year: $ 50
    Net rental income (loss): ($ 10)
    Cash Distribution: ($ 3)
    Debt relieved: ($ 12)
    1231 Gain: $ 100

    Outside basis: $ 125
  • veritas
    Senior Member
    • Dec 2005
    • 3290

    #2
    See worksheet

    pg 24-6 in TTB.

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