Monday, May 11, 2020

Zeus, Poseidon And The Wrath - 860 Words

Zeus, Poseidon and the Wrath / Love of Athena Zeus is the king of the gods on Olympus and human. Since he is the highest and powerful deity, he can mediate the conflicts of the gods. His action affects the fate of human beings. His most descendants are handsome, heroic, and powerful, in contrast with the descendants of Poseidon, as Zeus seems to be the absolute in the world. He sometimes helps Odyssey and allows Athena to help Odysseus to go back to his home. Nevertheless, he also respects Poseidon’s wrath to punish Odysseus and his people, which seems that it is more important for Zeus to preserve a good relationship with his brother Poseidon than he gives people, who are supplicating to go back to their home, a favor. Poseidon is the god of the sea. He sometimes seems to have inferiority complex against Zeus, brother of Poseidon. Poseidon wakes his wrath to disturb Odysseus going back to his home. This is because Odysseus makes the Cyclops Polyphemus, son of Poseidon, blind, and Poseidon was the patron of Troy which was defeated by Greek army in which Odysseus was a leader. In addition, Athena is not only the patron of Odysseus, but also the rival to Poseidon for the patron of Athens, so Athena won that position. These are able to be reasons of the wrath of Poseidon. Athena is the goddess of wisdom and battle, and she often shows her wisdom in Odysseus. She was Odysseus’ patron, so she helps Odysseus to go back to his palace. Also, she cares Telemachus in hisShow MoreRelatedThe Role Of Immortals And Gods In The Iliad By Homer1661 Words   |  7 PagesHomer is an epic poem that was set at the time of the Trojan War. The epic poem retells the events and the battles between Troy and Greek s tates during the attack of Troy. The epic focuses on the quarrels between Achilles and Agamemnon and Hera and Zeus. Achilles rage from the Iliad incorporates activities from the immortals as well as the gods. In the quarrel, Achilles through his anger, acted as a messenger from the gods to refute King Agamemnon’s greedy attribute that contributed to the defeatRead MoreA Common Characteristic Of Heroic Epic Literature965 Words   |  4 Pagesinteractions he has with some of the gods and goddesses and their offspring. His travels are negatively affected by his dealings with Polyphemus, son of Poseidon, and are positively affected through his interactions with the goddess of wisdom, Athena, and the messenger of the gods, Hermes. Though Odysseus does not deal directly with Poseidon, he purposefully spends time with Poseidon’s son, the Cyclops, Polyphemus. In his escapades, Odysseus is intent upon laying his eyes on the great CyclopsRead MoreThe Wrath of Poseidon in Odyssey Essay1951 Words   |  8 Pageshis entire crew and seemingly impossible task of getting home to his family. While journeying homewards, Odysseus makes the mistake of harming the Cyclops, who happens to be Poseidons son. Poseidon is so angry at Odysseus for the harm he inflicted on the Cyclops, that through the influence of all powerful Zeus, he punishes Odysseus along with his other children, the Phaeacians, who can be seen to parallel as well as contrast with the Cyclops. When he first sets out on his journey, Odysseus is settingRead MoreLightning Bolts, Dragons, And Sea Gods1094 Words   |  5 Pagesthe dragon, Poseidon the â€Å"earth shaker†, and many others. By using the Nature myth theory to analyze these myths, they can be used to explain natural occurrences. Even though other theories may also be used to explain myths, the Nature theory gives the most logical explanations for many myths like Zeus’s lightning bolts, Poseidon the â€Å"earth shaker†, and Typhoeus the dragon. The most popular Greek god in today’s society and even more popular in ancient Greek society is probably Zeus. Depicted asRead More The Gods in Homers The Iliad and The Odyssey Essay1393 Words   |  6 Pagescarried out to the extremes found in the Iliad. When Poseidon punishes Odysseys for blinding the Cyclopes, Athena does not take revenge. Even though Odysseys is her favorite human, she respects Poseidons right to punish him. In addition, the betrayal among the Gods that is so prevalent in the Iliad, is nowhere to be found in the Odyssey. In Iliad, Hera, enters into a plan with Poseidon, Aphrodite, and Morpheus to aid the Greeks by putting Zeus to sleep thus rendering him unable to help his belovedRead MoreWho Motivates Odysseus Analysis950 Words   |  4 Pagescharacter, Odysseus, is motivated to return home by the courage he receives from the goddess, Athena. The first instance the reader encounters the wise goddess, Athena, helping Odysseus, she is advocating to the gods for his return home. Athena pleads to Zeus, in hopes that Odysseus will be able to return home. â€Å"Think: not one of the people whom he ruled remembers Odysseus now, that godlike man, and kindly father to his children. Now he’s left to pine of an island†¦ He has no way to voyage home to hisRead MoreVirtue Of Hospitality : Homer s Odyssey And The Holy Bible990 Words   |  4 Pagesstranger’s house and allowing strangers to stay in their own homes. The palaces that Odysseus’ seeks shelter in are chosen not only for their hospitable hosts, but also for their abilities to protect him from his enemies; namely, Poseidon. After barely surviving the wrath of the Earth Shaker and his turbulent seas (Homer 50), Odysseus finally washes up on the shores of Phaecia. While nude and untidy, he encounters the Phaeacian princess, Nausicaa. Despite his condition, Nausicaa graciously informsRead MoreThe Between Greek City And Their Patron Gods1269 Words   |  6 PagesWhen an in depth look at a hinged on war is performed, it is found that the god which Sparta associated herself with the most was Apollo and Ares. To further concrete a point, Ares is the Greek god of war. A formidable opponent, Ares is the son of Zeus and Hera. As a war driven society based upon the principles of hierarchy and superiority, it is only justice that Sparta would choose the warrior son of the King and queen of the Gods to be their patron deity. One Spartan custom that proves that warRead MoreDivine Intervention in the Iliad1550 Words   |  7 Pagespoem we find so many Devine interventions in human activities .The interventions of t he gods also serve to magnify the significance of human action. Infect, the epic begins with one of the divine intervention. In book I,which is named as PLAGUE AND WRATH, Apollos intervention on Chryses behalf begins the series of events that continue throughout the epic.When Chryses come to Greek’s swift ship to recover his captured daughter Chryseis .Chryses offers a ransom for his daughter which Agamemnon brutallyRead MoreThe History and Life of Poseidon1277 Words   |  6 PagesPoseidon is one of the strongest gods in Greek mythology. Poseidon was the god of water, horses, and earthquakes. He was thought to be the reason for boat wrecks, and drowning’s. Cronus and Rhea are the parents of Poseidon in Greek mythology. Poseidon is one of the 3 sons; the others are Hades and Zeus. And their three sisters were Demeter, Hestia, Hera, and while Cronus was the horrible father who feared his own children so he ate them at birth. He continued to eat the newborns until his wife

Wednesday, May 6, 2020

South-Western Federal Taxation Comprehensive Volume Free Essays

CHAPTER 21 PARTNERSHIPS SOLUTIONS TO PROBLEM MATERIALS | | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | LO 1Partnership definitionNew 2LO 2General partnership versus LLCNew 3LO 1Check-the-box regulationsNew 4LO 2Partnership tax reportingModified1 5LO 2Analysis of Income scheduleModified1 6LO 2Partnership Schedule M-3New 7LO 3Special allocationsNew 8LO 3Capital accountsNew 9LO 3Inside versus outside basisNew 10LO 4Comparison of corporate and partnershipUnchanged2 treatment 11LO 4Application of  § 721New 12LO 4Exceptions to  § 721New 13LO 4Disguised sale issue recognitionUnchanged4 14LO 5Initial costs of a partnershipNew 15LO 6Cash accounting method for partnershipsNew 16LO 7Economic effect testUnchanged8 7LO 8Adjustments to partner’s basisUnchanged9 18LO 8Liability allocations to basisUnchanged10 19LO 10Guaranteed paymentsNew 20LO 8, 9, 14Partnership advantages and disadvantagesUn changed12 21LO 4, 6, 7,Partnership formation and operationsUnchanged13 8, 9, 10issues 22LO 11Basis in distributed propertyUnchanged14 23LO 11Distribution ordering rules; liquidatingNew versus nonliquidating distributions 24LO 11Conceptual: tax results of distributionsNew 25LO 12Ramifications of sale of a partnership interestNew Instructor: For difficulty, timing, and assessment information about each item, see p. 1-4. | | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | 6LO 4Formation of partnership; inside and basisUnchanged15 27LO 4, 14Formation of partnership; inside and outsideUnchanged16 outside basis 28LO 4Contribution of various properties onUnchanged17 formation of a partnership; basis and depreciation 29LO 4Formation of a partnershipNew 30LO 4Formation of a partnershipNew 31LO 4, 8, 14Basis of property received as gift; receipt Modified19 of interest for services 32LO 8, 14Planning fo r service interestsNw 33LO 4, 10, 14Disguised sale versus distributionUnchanged20 *34LO 4, 7Treatment of contributed propertyNew 5LO 5Tax issues related to formation ofUnchanged5 partnership 36LO 4, 5, 6,Preparation of initial LLC tax returnUnchanged6 37LO 6Accounting methodsUnchanged7 *38LO 5Definition of organization costs;Unchanged21 amortization of organization costs *39LO 6Computation of partnership’s required taxUnchanged24 year under the least aggregate deferral method 40LO 4, 7Date basis of partner’s interest; gain on saleUnchanged25 of contributed land with precontribution built-in gain 41LO 7Date basis of partner’s interest; loss on saleUnchanged26 of contributed land *42LO 7, 8Computation of partner’s outside basis atModified27 beginning and end of year when several transactions took place *43LO 7, 8Partnership income; partner’s basis;Modified28 separately stated items; guaranteed payments 44LO 7, 8, Partnership income; partner’s basis; lossModified29 10,limitations; guaranteed payments 45LO 4, 7, 8Partnership’s income and separately statedUnchanged30 items; partner’s basis and amount at risk 6LO 4, 7, 8Same as Problem 45 for an LLCModified31 47LO 7, 8, 9,Basis and loss limitationsUnchanged32 *48LO 4, 7, 8,Allocations under  § 704(b)Modified33 9 49LO 7, 8, 9Allocation of gain under  § 704(b)Modified33 50LO 7, 8, 9Allocations to partner; basis in interest; Unchanged34 loss limitations 51LO 8Allocation of recourse debtUnchanged35 52LO 4, 8Sharing recourse debt for basis purposesUnchanged36 Instructor: For difficulty, timing, and assessment information about each item, see p. We will write a custom essay sample on South-Western Federal Taxation: Comprehensive Volume or any similar topic only for you Order Now 21-4. | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | 3LO 8, 9, 14Basis calculations and loss limitationsUnchanged11 54LO 8, 9Loss disallowance under  § 704(d),  § 465,Unchanged37 and  § 469 55LO 7, 10Timing of recognition of guaranteedModified38 payments 56LO 10Timing of recognition of guaranteed New payments, continued *57LO 7, 10Comparison of C corporation salary versus Unchanged39 partnership guaranteed payment 58LO 10Disallowed  § 267 loss from sale of propertyUnchanged40 to partnership by partner; conversion f capital gain to ordinary income from sale of investment property to partnership by partner 59LO 11Nonliquidating distribution; basis of New assets distributed (limited); partner’s outside basis 60LO 11Nonliquidating distribution; basis of New assets distributed (limited); partner’s outside basis *61LO 11Nonliquidating distributions; amount andModified43 nat ure of gain or loss; basis of assets distributed; partner’s outside basis *62LO 11Allocation of basis to multiple assetsUnchanged44 distributed 3LO 11Effect of change in partner’s share of New liabilities; nonliquidating versus liquidating distributions 64LO 11Results of various liquidating distributionsUnchanged45 65LO 12Sale of partnership interest; amount andModified46 nature of gain or loss; basis of new partner’s interest; election to adjust basis of partnership property *The solution to this problem is available on a transparency master. Instructor: For difficulty, timing, and assessment information about each item, see p. 21-4. | | | |Status: | |Q/P | | Research | | | |Present | |In Prior | |Problem | |Topic | |Edition | |Edition | | | | | | | | | 1Economic effect allocationsUnchanged1 2Allocation of liabilitiesNew Internet activityUnchanged3 | | |Est’d | |Assessment Information | | |Question/ | |completion |AICPA* | AACSB* | |Problem |Difficulty |time |Core Comp | Core Comp | | | | | | | | | | 2 |Easy | |10 |FN-Reporting |Analytic | | 3 | |Easy | |10 |FN-Reporting |Analytic | | 4 | |Easy | |10 |FN-Reporting |Analytic | | 5 | |Medium | |10 |FN-Reporting |Analytic | | 6 | |Medium | |10 |FN-Reporting |Analytic | | 7 | |Easy | |10 |FN-Reporting |Analytic | | 8 | |Medium | |10 |FN-Reporting |Analytic | | 9 | |Easy | |10 |FN-Reporting |Analytic | | 10 | |Medium | |10 |FN-Reporting |Analytic | | 11 | |Easy | |10 |FN-Reporting |Analytic | | 12 | |Medium | |10 |FN-Reporting |Analytic | | 13 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 14 | |Medium | |10 |FN-Reporting |Analytic | Reflective Thinking | | 15 | |Medium | |10 |FN-Reporting |Analytic | | 16 | |Easy | |10 |FN-Reporting |Analytic | | 17 | |Easy | |10 |FN-Measurement |Analytic | | 18 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 19 | |Easy | |10 |FN-Reporting Analytic | | 20 | |Medium | |10 |FN-Measurement | FN-Reporting | Analytic | | 21 | |Medium | |15 |FN-Reporting |Analytic | | 22 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 23 | |Easy | | 5 |FN-Measurement | FN-Reporting |Analytic | | 24 | |Easy | | 5 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 25 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 26 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 27 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 28 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 29 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 30 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 31 | |Hard | |15 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | | |*Instructor: See the Introduction to this supplement for a discussion of using AICPA and AACSB core competencies in assessment. | | 32 | |Medium | |10 |FN-Reporting |Analytic | Reflective Thinking | | 33 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 34 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 35 | |Medium | |10 |FN-Measurement | FN-Reporting Analytic | Reflective Thinking | | 36 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 37 | |Medium | |10 |FN-Reporting |Analytic | | 38 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 39 | |Medium | |10 |FN-Reporting |Analytic | | 40 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 41 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 42 | |Medium | |20 |FN-Measurement | FN-Reporting |Analytic | | 43 | |Hard | |15 |FN-Measurement | FN-Reporting |Analytic | | 44 | |Hard | |15 |FN-Measurement | FN-Reporting |Analytic | | 45 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 46 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 47 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 48 | |Medium | |10 |FN-Measu rement | FN-Reporting |Analytic | Reflective Thinking | | 49 | |Hard | |10 |FN-Measurement FN-Reporting |Analytic | | 50 | |Hard | |15 |FN-Measurement | FN-Reporting |Communication | Analytic | | 51 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 52 | |Hard | |15 |FN-Measurement | FN-Reporting |Communication | Analytic | | 53 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | Reflective Thinking | | 54 | |Hard | |15 |FN-Measurement | FN-Reporting |Communication | Analytic | | 55 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | | |*Instructor: See the Introduction to this supplement for a discussion of using AICPA and AACSB core competencies in assessment. | 56 | |Medium | |10 |FN-Reporting |Analytic | | 57 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 58 | |Easy | |10 |FN-Measurement | FN-Reporting |Analytic | | 59 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 60 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 61 | |Medi m | |10 |FN-Measurement | FN-Reporting |Analytic | | 62 | |Medium | |10 |FN-Measurement | FN-Reporting |Analytic | | 63 | |Medium | | 5 |FN-Measurement | FN-Reporting |Analytic | | 64 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | 65 | |Medium | |15 |FN-Measurement | FN-Reporting |Analytic | | | |*Instructor: See the Introduction to this supplement for a discussion of using AICPA and AACSB core competencies in assessment. | CHECK FIGURES 26. a. $0; $0. 26. b. $200,000. 26. c. $100,000. 26. d. $100,000 basis in property. 27. a. ($15,000) realized; $0 recognized. 27. b. $60,000. 27. c. $75,000. 27. d. $75,000. 27. e. Sell and contribute cash. 28. a. $20,000 on land; $60,000 on equipment. 28. b. No gain under  § 721. 28. c. Carol $70,000; Connie $30,000. 28. d. $40,000 basis in land; $30,000 basis in equipment. 28. e. Inside = Outside = $100,000. 28. f. Partnership continues Connie’s depreciation schedule. 29. No gain or loss to Justin, Tiffany, or partnership; Justin’s basis $85,000; Tiffany’s basis $125,000; partnership’s basis in land $65,000; partnership steps into Tiffany’s shoes for depreciation. 30. Tiffany recognizes $25,000 loss on sale; basis is $100,000. Partnership must spend additional $10,000 to acquire assets. 31. a. $0. 31. b. $50,000. 31. c. $25,000 ordinary income. 31. d. $75,000. 32. b. Contribute ‘‘property’’ of ‘‘permits’’ and ‘‘development plan’’ completed before contribution. 33. a. Distribution. 33. b. $0 gain or loss. 33. c. $50,000. 33. d. Disguised sale. 33. e. $16,667. 33. f. $66,667. 34. a. Rachel $360,000; Barry $600,000. 34. b. 170,000 ordinary income. 34. c. $100,000 capital loss and $20,000 ordinary loss. 35. Organization costs $10,000 (deducted); start-up costs $60,000 (amortized over 180 months); property acquisition costs $24,000 (added to property b asis; depreciated as newly acquired asset); syndication costs $1 million (nondeductible). 36. Issues include partnership year end; partnership accounting method; treatment of initial costs; partners’ bases in LLC interests; LLC’s basis in property received on formation; interests issued in exchange for services; built-in gain on later sale of land. 37. BR can use cash, accrual, or hybrid method in 2008, 2009, and 2010. In 2011 and later years, BR may no longer use cash method. 38. a. Organizational costs: $8,000; syndication costs $10,000. 38. b. $5,000 deduction plus $50 amortization of organization costs. 38. c. 180-month amortization. 39. January 31. 40. a. $75,000. 40. b. Five years. 40. c. $15,000 gain. 41. a. $36,000 loss; $30,000 to Reece and remaining $6,000 allocated equally among partners. 42. a. $160,000. 42. b. $230,000. 43. a. $42,000; qualified dividends $4,000. 43. b. $29,000 basis. 43. c. $22,000 basis. 44. a. ($18,000); qualified dividends $4,000. 44. b. $0 basis; $8,000 loss deductible currently, $1,000 suspended. 44. c. $0 basis; $1,000 loss allowed; $8,000 suspended. 45. a. 175,000 (Celeste); $125,000 (Ernestine). 45. b. Ordinary income $80,000; qualifying dividend $3,000; tax-exempt interest $1,000; charitable contribution $500; distribution to Celeste $20,000. 45. c. $283,500 basis and at-risk amount. 46. a. Accounts payable are nonrecourse for LLC. 46. b. $283,500 basis; $233 ,500 amount at risk. 47. a. $24,000. 47. b. $4,000. 47. c. $0. 47. d. $4,000. 47. e. Don can contribute capital or partnership can incur debt. 48. a. Year 1—Fred $49,600; Manuel $78,400. Year 2—Fred $960; Manuel $75,840. 48. b. Yes. 49. a. Gain $43,200 allocated equally. Basis—Fred $22,560, Manuel $97,440. 49. b. Fred’s cash $22,560; Manuel’s cash $97,440. 49. c. Tax savings now or cash later; not both. 50. Deduct $54,000 of loss unless basis increased before year-end. 51. Melinda $6,000; Gabe $6,000; Pat $18,000. 52. Paul $160,000; Anna $80,000. 53. a. Basis adjustment rules per Figure 21. 3; then loss limitation rules [ § 704(d),  §Ã‚  465, then  § 469]. 53. b. $5,000 gain, $0 basis. 53. c. No loss deduction. 53. d. Make distribution next year so Brad can deduct loss this year. Partnership can incur additional debt. 54. $48,000 deducted. $14,000 suspended— § 704(d); $8,000 suspended— § 469. 55. a. $70,000 in 2010, incl. guaranteed payment. 55. b. $25,000 in 2010. 56. $70,000. 57. a. $55,000 salary in 2010. 57. b. 0 in 2010; $40,000 partnership income and $60,000 guaranteed payment in 2011. 58. a. $0. 58. b. $10,000. 58. c. $80,000 gain; may be ordinary. 59. a. $0. 59. b. $0. 59. c. Inventory $60,000; land $75,000; partnership interest $185,000. 60. a. $0. 60. b. $0. 60. c. Account receivable $0; land $20,000; partner ship interest $0. 61. a. $15,000 gain and basis in partnership interest $0; partnership $0 gain. 61. b. Land $30,000 basis and basis in partnership $10,000; partnership $0 gain. 61. c. No gain or loss; land basis $12,000; basis in partnership interest $0. 61. d. $10,000 gain; $0 basis in inventory; $0 basis in partnership interest. 62. a. No gain or loss. 62. b. 6,000 in item 1 and $3,000 in item 2. 63. a. Inventory basis $10,000; basis in partnership interest $20,000. 63. b. Recognized loss $20,000; Inventory basis $10,000. 64. a. $15,000 capital gain. 64. b. No gain or loss; $40,000 basis. 64. c. No gain or loss; inventory $10,000; capital asset $22,000. 64. d. $0 basis in accounts receivable; $60,000 capital loss. 65. a. $100,000 realized. 65. b. $30,000 ordinary income. 65. c. $20,000 capital gain. 65. d. $100,000 basis. DISCUSSION QUESTIONS 1. A partnership is an association of two or more persons (including individuals, trusts, estates, corporations, other partnerships, etc. ) formed to carry on a trade or business. Each partner contributes money, property, labor or skill, and each expects to share in profits and losses. The entity must not otherwise be classified as a corporation, trust, or estate. p. 21-3 2. In a general partnership, all partners are â€Å"general partners† who are jointly and severally liable for partnership debts, including liabilities arising from tort or malpractice judgments against the general partnership. A general partner bears liability for these debts even if the partner was not personally involved in the malpractice. A limited liability company has the corporate attribute of limited liability for the owners (called â€Å"members† in an LLC), but an LLC is treated as a partnership for tax purposes. In a properly-structured LLC, none of the members are personally liable for entity debts. State law governs the types of entities that may be established as LLCs. Most states permit capital-intensive entities to use this form of business, but they do not permit personal-service entities to be treated as LLCs. pp. 21-3 and 21-4 3. By default, a newly-formed noncorporate entity with two more owners is treated as a partnership under the check-the-box Regulations. The entity may â€Å"check-the-box† on Form 8832 to elect, instead, to be taxed as a corporation. p. 21-4 4. A partnership is not a tax-paying entity; however, it must still file a tax return. The partnership reports its income and expenses on Form 1065. Partnership income is comprised of income from operations and separately stated income and expenses. The income and expenses from operating activities are reported on Page 1 of the Form 1065. A separately stated item is any item (income or expense) that could differently affect the tax liabilities of different partners. Separately stated items are reported in the partnership return on Schedule  K. The partners must pay the tax on the partnership income. The partnership’s income and separately stated items are reported to each partner on a Schedule K-1 prepared for that partner. pp. 21-4 to 21-7 5. Because it is not a tax-paying entity, a partnership does not report â€Å"taxable income. † However, it must still reconcile between the tax return and the books. The partnership prepares the Analysis of Net Income (Loss) (page 5 of Form 1065) to determine what might be called the partnership’s â€Å"taxable income equivalent. † Certain amounts shown on Schedule K are netted and entered on the Net Income (loss) line of this Analysis. This â€Å"taxable income equivalent† is reconciled to book income on Schedule M-1 or Schedule M-3 of the partnership’s return. This is similar to the corporate reconciliation (also on Schedule M-1 or M-3) in Form 1120; however, for a partnership, the â€Å"taxable† amount must be derived as described above. pp. 1-5 to 21-7 6. Schedule M-3 is filed (in lieu of Schedule M-1) by â€Å"larger† partnerships to report a detailed reconciliation between the partnership’s book and tax income. In addition, these partnerships must file Schedule C to answer various questions regarding the partnership’s changes of ownership, reporting, or other activities during the year. This reconciliation is designed to highlight differences between GAAP basis reporting (per an SEC filing or an audited financial statement) and tax basis income. A partnership is generally required to file Schedule M-3 if it has $10 million or more in assets or $35 million or more in total receipts. In addition, it must file Schedule M-3 if any partner owns a 50%-or-greater interest in partnership profits, losses, or capital, and if that partner meets either the $10 million (assets) or $35 million (receipts) threshold. pp. 21-6 and 21-7 7. A special allocation is an amount that is allocated differently from the general profit or loss sharing ratios specified in the partnership agreement. For pre-contribution gain or loss property, special allocations are required to be made to eventually bring the partners’ tax bases in line with their book-value capital accounts. Orange, LLC, can offer a preferential special allocation of profits and cash flows to Green to compensate the company for use of its capital. The LLC can offer a guaranteed payment (rather than a special allocation) to Rose for her managerial time and expertise. Upon sale of the appreciated property contributed by Rose,  §Ã‚  704(c) requires the precontribution gain to be allocated to her. pp. 21-8, 21-24, and 21-36 8. A partner’s capital account is a mechanical determination of the partner’s financial interest in the partnership, as determined using one of several possible accounting methods, including tax basis, GAAP,  §Ã‚  704(b) book basis, or some other method defined by the partnership. The capital account reflects contributions and distributions of cash or other property to or from the partner. In addition, it accumulates the partner’s share of increases and decreases from operations, including amounts that are otherwise tax-exempt or nondeductible. Even if capital accounts are determined on a tax basis, a partner’s capital account usually will differ from the partner’s basis in the partnership interest because (among other reasons) the capital account does not include the partner’s share of partnership liabilities. p. 21-8 9. The â€Å"inside basis† is the partnership’s tax basis for the assets it owns. The â€Å"outside basis† is a given partner’s tax basis in the partnership interest. On formation of a partnership, the total of all partners’ outside bases will equal the partnership’s inside bases of all of its assets. p. 21-8 10. As a general rule, both  §Ã‚ §Ã‚  721 and 351 provide that no gain or loss is recognized when property is transferred on the formation of a partnership or corporation. However,  §Ã‚  351 applies only if those persons transferring property to a corporation are in control of the corporation immediately after the exchange, whereas  §Ã‚  721 does not include a control requirement. Section 721 not only applies to initial transfers in forming the partnership but to all subsequent contributions from any partner. Similarities exist between  §Ã‚ §Ã‚  721 and 351 in that these nonrecognition provisions do not apply to all transfers made by the owners. Under  §Ã‚  721, the contributor must receive an interest in the partnership, while under  §Ã‚  351, the transferor must receive stock in the corporation. Under both  §Ã‚ §Ã‚  721 and 351, if the transfer of property involves the receipt of money or other consideration, the transaction may be deemed a sale or exchange rather than a tax-free transfer. pp. 21-9 to 21-11, and Concept Summary 21. 1 11. In general, on formation of a partnership, no gain or loss will be recognized by either the partnership or the contributing partners [ §Ã‚  721]. Bobbi will not recognize the realized gain related to the land she is contributing. Similarly, BC will not recognize a gain or loss. Bobbi’s basis in the land will carry over to BC. Bobbi’s basis in BC will be a substituted basis equal to her basis in the contributed land. If the land Bobbi contributes is ever sold by BC, the precontribution gain must be allocated to Bobbi [ §Ã‚  704(c)]. pp. 21-9, 21-10, and Example 24 12. Under the general rule of  §Ã‚  721(a), no gain or loss is recognized on formation of a partnership. This rule does not apply in at least four situations. Realized gain or loss is recognized if: †¢ The entity is an investment partnership, †¢ The partner received the interest in the partnership in exchange for services, †¢ The transaction can be viewed as an exchange of properties (e. g. , properties are contributed to the partnership and soon thereafter are distributed to other partners with the intent of taking advantage of the basis rules of  §Ã‚  731 for distributed property), and †¢ The transaction can be viewed as a disguised sale of the property from the partner to the partnership or one of the other partners. pp. 21-10 to 21-11 13. a. If a contribution of property to a partnership is followed shortly thereafter by a distribution of cash to that partner, the IRS may recharacterize the transactions as a disguised sale of the property. In this case, Gerald would be treated as contributing 75% of the property and selling the remaining 25% for cash [$60,000 sales price (distribution amount) ? $240,000 property value]. He would recognize $30,000 of gain on the deemed disguised sale [$60,000 deemed selling price less $30,000 basis ($120,000 ? 25%)]. b. The parties could use any of several techniques to minimize the possibility that the IRS will recharacterize the transaction as a sale. First, the distribution could be proportionate to all the partners. Second, the contribution should not be contingent on the later distribution of cash. Third, even if cash is required to ensure the contribution, the distribution should not be contingent on the partnership achieving a certain level of profits. Fourth, the distribution could be made in stages over a longer (say, three-year) time period. Here, it may be viewed as being a reasonable return of Gerald’s capital (e. g. , each $20,000 payment represents a 10% return on his capital). Finally, the distribution could be deferred until two years following the capital contribution. pp. 21-11, 21-12, and Example 12 14. In its initial year, a partnership will typically incur organizational and startup expenses. If property is contributed to the partnership, the entity may incur costs related to transferring the title of the property. If the partnership interests are sold to investors, the partnership might incur syndication costs. Once the partnership has started business, it will incur ordinary and necessary business expenses; these expenses are deductible under  §Ã‚  162. Organizational and startup costs are generally deductible to the extent of the first $5,000 of such costs. This deductible amount is reduced to the extent the total of such costs (in the respective category) exceeds $50,000. Any portion that is not deductible is amortized over 180 months, beginning with the month in which the partnership begins business. The cost of selling the partnership interests to investors is treated as a syndication cost under  §Ã‚  709. Such expenses are not deductible. The cost of transferring title to an asset is treated as an acquisition cost related to the asset; this amount will be treated as a new asset placed in service when incurred, and it will be depreciated using the same method and life as the underlying property. (If this underlying property was contributed by a partner, that property will be depreciated by continuing the depreciation schedule used by the contributing partner. The partnership â€Å"steps into the shoes† of the contributing partner in calculating depreciation deductions. ) pp. 21-15 and 21-16 15. A partnership may generally use the cash method of accounting unless it is a tax shelter or has one or more partners that are subchapter C corporations. The C corporation partner will not preclude use of the cash method of accounting if that corporation is a qualified personal service corporation or if it is engaged in the farming business. In addition, a subchapter C corporate partner will not preclude use of the cash method if the partnership has never had â€Å"average annual gross receipts† in excess of $5 million, for any year beginning in 1986 or later years. Average annual gross receipts is calculated by averaging the taxpayer’s gross receipts for the three years prior to the tax year in question or for the period of the taxpayer’s existence, if shorter. p. 21-17 16. The three rules of the economic effect test are designed to ensure that a partner bears the economic burden of a loss or deduction allocation and receives the economic benefit of an income or gain allocation. By increasing the partner’s capital account by the gain or income allocated to the partner, the rule ensures that a positive capital account partner will receive an allocation of assets equal to the balance in the partner’s capital account when the partner’s interest is eventually liquidated. If the partner has a negative capital account, an allocation of gain or income to the partner reduces the amount of the negative capital account and, therefore, the amount of the deficit capital contribution that is required from the partner upon liquidation. In short, a dollar of income or gain increases the partner’s capital account by a dollar and, everything being equal, the partner should receive a dollar more upon liquidation (or contribute a dollar less to restore a deficit in the capital account). Allocations of losses and deductions affect the partner in the opposite manner as income or gain. Therefore, the allocation of a dollar of loss or deduction reduces the partner’s capital account by a dollar and, everything being equal, reduces the amount the partner will receive upon liquidation (or increases by a dollar the partner’s deficit capital restoration requirement). p. 21-23 and Example 22 17. Under  § 722, a partner’s initial basis is determined by reference to the amount of money and the basis of other property contributed to the partnership. This basis is increased by any gain recognized under  § 721(b) and the partner’s share of any partnership liabilities. Basis is decreased by any partner liabilities assumed by the partnership. Basis is also adjusted to reflect the effect of partnership operations: it is increased by the partner’s share of taxable and nontaxable income and is decreased by the partner’s share of loss and nondeductible/noncapitalizable expenses. Certain adjustments for depletion are also made. Finally, a partner’s basis is increased by additional contributions to the partnership and by increases in the partner’s share of partnership debt. Basis is decreased by distributions from the partnership and decreases in the partner’s share of partnership debt. A partner’s basis is adjusted any time it may be necessary to determine the basis for the partnership interest, for example, when a distribution was made during the taxable year, or at the end of a year in which a loss arises. A partner’s basis may never be reduced below zero (i. e. , no negative basis). Figure 21. 3 18. The partnership’s debts are allocated to the partners in determining the partners’ bases in their partnership interests. Any increase in partnership liabilities is treated as a cash contribution to the partnership, thereby increasing the partners’ bases. Any decrease in partnership liabilities is treated as a distribution from the partnership to the partners and decreases their bases. Partnership debt is allocated differently depending on whether it is recourse to the partners or nonrecourse. Recourse debt is allocated in accordance with the constructive liquidation scenario. Under this test, all partnership assets are deemed to be worthless. The losses that would arise are allocated to the partners according to the partnership agreement. The losses would create negative capital accounts for at least some of the partners; those partners are deemed to contribute that amount of cash (equal to the negative capital balance) to the partnership in settlement of the obligation to repay partnership’s recourse liabilities. The amount of that deemed capital contribution is the amount of the partner’s share of the recourse liabilities. Nonrecourse debt is allocated in a three-tier system. First, allocate any gain related to assets where the debt exceeds the partnership’s â€Å"book† basis in the assets. This is called minimum gain and is allocated according to the partnership agreement. Next, any debt related to any remaining precontribution gain is allocated to the partner who contributed the encumbered property to the partnership. Finally, any remaining debt is allocated in accordance with the method specified in the partnership agreement. pp. 21-28 and 21-29 19. A guaranteed payment is an amount paid to a partner for the performance of services or for the use of the partner’s capital. These payments are in the nature of salary or interest payments that are made by other entities, but the tax treatment of guaranteed payments is somewhat different. Like payments made by other entities, guaranteed payments are generally deductible by the partnership, and can result in a loss to the entity. Guaranteed payments are taxed as ordinary income to the recipient partner. Unlike salary and interest payments made by other entities, guaranteed payments are treated as if they were received by the partner on the last day of the partnership’s tax year. If the partner and partnership have different tax years, there will be a deferral between the time the partnership claims the deduction and the time the partner reports the income. Guaranteed payments are treated as self-employment income by the recipient partner. pp. 21-36 and 21-37 20. A partnership is advantageous under any of the following conditions: †¢ Special allocations of income, expenses, cash flows, etc. can be made by the entity owners. †¢ The entity has taxable losses which the owners can utilize on their individual tax returns. †¢ The partnership generates net passive income which offsets passive losses of the owners. The entity operated as a Subchapter C corporation and would be required to report taxable income since other means of reducing such income (e. g. , interest, rents, salaries to owners) have been maximized and are not available. †¢ The entity cannot qualify under the requirements for a Subchapter S election (e. g. , too many shareholders, nonqualifying shareholders, more than one outstanding class of stock, etc. ) †¢ The entity will exist for only a short period of time and, if a corporation, its liquidation will result in a large tax due to the appreciation in its assets. †¢ Several other advantages may exist. The disadvantages of the partnership entity form arise when: The entity income is significant and will be taxed at higher individual rates than if accumulated in the corporation. †¢ The entity is in a high risk business and the owners require protection from personal liability. An LLC or LLP may be useful in such situations. pp. 21-51, 21-52, and Concept Summary 21. 5 21. a. False. The entity is required to file an information return, generally by the fifteenth day of the fourth month after the end of the partn ership’s tax year. The return includes data concerning the partners’ allocable shares of the financial activities of the partnership. In addition, property, sales, and employment tax returns are likely to be required of the entity. p. 21-6 b. False. Generally no gain or loss is recognized, but there are exceptions to  § 721, including those pertaining to the receipt of boot, the contribution of property with liabilities in excess of basis, and the receipt of a partnership interest in exchange for services provided to the partnership. pp. 21-10 and 21-11 c. False. The partner recognizes ordinary income, to the extent of the fair market value of the partnership interest that is received in this manner. p. 21-11 d. False. If property which was inventory in the hands of the transferor partner is sold by the partnership within five years of the date it was contributed, any gain will be treated as ordinary income, regardless of the manner in which the property was held by the partnership. p. 21-13 e. False. The partnership chooses tax accounting periods and methods that are applied to all of the partners. p. 21-15 f. False. An alternative tax year will never be required by the IRS; instead, the partnership must request permission from the IRS and may have to illustrate to the IRS that it has a business purpose for using an alternative tax year. p. 21-19 g. True. Built-in losses, as well as gains, must be allocated to the contributing partner when recognized by the partnership. pp. 21-24 and 21-25 h. True. pp. 21-27 to 21-29 i. True. p. 21-33 j. False. Such losses can be deducted by partners who hold a 50% or less ownership interest in the entity. p. 21-38 22. Generally, a taxable gain arises on a proportionate distribution only when cash is received in excess of the distributee partner’s basis in the partnership interest. As a relief of liabilities is treated as a distribution of cash, a decrease in a partner’s share of liabilities may also trigger a taxable gain. Similarly, certain distributions of marketable securities are treated as distributions of cash and can result in gain recognition. Other transactions, such as disguised sales and distributions related to precontribution gain property, might also result in gain recognition by the distributee partner. pp. 21-41 and Examples 51, 52 and 57 23. In either a current or liquidating distribution, assets are distributed in the following order: 1)  cash, 2) ordinary-income producing (hot) assets, and 3) other assets. Cash. In either a current or liquidating distribution, a cash distribution in excess of the partner’s basis triggers a gain (typically a capital gain). Cash (and certain items treated as cash) is the only asset for which a distribution might trigger a gain. Hot assets. In either a current or liquidating distribution, the partner’s basis in distributed hot assets equals the lesser of the partner’s basis in the partnership interest (after any cash distributions) or the partnership’s basis in the hot asset. In a liquidating distribution, the partner can claim a loss equal to any basis remaining after these hot assets are distributed, if no â€Å"other assets† will be distributed. In a current distribution, no loss can be deducted. Other assets. In a current distribution, â€Å"other assets† are treated similarly to hot assets: the basis equals the lesser of the partner’s basis in the partnership interest (after any cash and hot asset distributions) or the partnership’s basis in the asset. In a liquidating distribution, â€Å"other assets† absorb any remaining basis in the partnership interest after cash and hot assets are accounted for. For either a current or liquidating distribution, if â€Å"other assets† are distributed, the partner cannot recognize a loss. Examples 54, 57, 59, and 60 24. The partnership distribution rules reflect the aggregate theory of taxation. With respect to property ownership, the partner can be seen as an extension of the partnership. Ownership of property by the partner generally produces the same result as ownership by the partnership (and vice versa). The result is a carryover basis in distributed property with a preservation of the character of distributed property. The distribution rules operate with the goal of deferring tax on the distribution, while preserving the ordinary income potential. No gain or loss is recognized if an adjustment can be made to the basis of the distributed property, without reducing the amount of ordinary income the partner will eventually recognize. So, gain is recognized if cash distributions exceed basis, because there is no asset for which the basis can be reduced. The basis of hot assets can be decreased, but not increased, in a distribution because the inherent ordinary income cannot be decreased. Similarly, loss can be recognized if only cash and â€Å"hot† assets are received in a liquidating distribution, because the basis in these types of assets cannot be increased to absorb the partner’s remaining basis. pp. 21-40 and 21-41 25. Jody must determine her gain or loss on the sale of the partnership interest. If the partnership owns â€Å"hot assets,† she must recognize ordinary income or loss to the extent of her proportionate share of the built-in appreciation or depreciation on these assets. Her remaining gain or loss is adjusted by the ordinary income or loss recognized. If the partnership’s assets are substantially appreciated, Bill may wish to ask the partnership to make a  § 754 election so he can be allocated a step-up in basis. If the partnership has a substantial built-in loss (assets are depreciated by more than $250,000), the partnership may be required to make a step-down adjustment with respect to Bill’s acquired interest. If Jody sells more than a 50% interest in the partnership, or Bill is the sole remaining member of a two-owner partnership, the entity will terminate on the date the purchase is finalized. This may result in a loss of a favorable tax year or accounting method by the partnership. pp. 21-47 to 21-49 PROBLEMS 26. a. Under  § 721, neither the partnership nor the partners recognizes any gain on formation of the entity. b. Chip will take a cash basis of $200,000 in his partnership interest. c. Marty will take a substituted basis of $100,000 in his partnership interest ($100,000 basis in the property contributed to the entity). d. The partnership will take a carryover basis in the assets it receives ($200,000 basis in cash, and $100,000 basis in property). Example 14 27. a. Liz has a realized loss of $15,000. However,  § 721 contains the general rule that no gain or loss is recognized to a partnership or any of its partners upon the contribution of money or other property in exchange for a capital interest. Since Liz is subject to this rule, she does not recognize the loss. p. 21-10 b. $60,000. Section 722 provides that the basis of a partner’s interest acquired by a contribution of property, including money, is the amount of such money and the adjusted basis of such property to the contributing partner at the time of the contribution. p. 21-12 c. $75,000, the adjusted basis of the contributed property ( § 722). p. 21-12 d. $75,000. Under  § 723, the basis of property to the entity is the adjusted basis of such property to the contributing partner at the time of the contribution, increased by any  §Ã‚  721(b) gain recognized by such partner. Since no such gain (and no loss) was recognized by Liz on the contribution, the partnership takes a carryover basis in the property. Example 14 e. A more efficient tax result may arise if Liz sells the property to an unrelated party for $60,000, recognizes the $15,000 loss on the property, and contributes $60,000 cash to the partnership. The partnership could then use the $60,000 to acquire similar property, in which it would take a $60,000 basis. Example 9 28. a. Carol realizes a gain of $20,000 on contribution of the land. Connie realizes a gain of $60,000 on contribution of the equipment. The partnership realizes a gain equal to the value of the property it receives (it has a $0 basis in the partnership interests it issues). b. Under  § 721, neither the partnership nor either of the partners recognizes any gain on formation of the entity. Example 8 c. Carol will take a substituted basis of $70,000 in her partnership interest ($30,000 cash plus $40,000 basis in land). Connie will take a substituted basis of $30,000 in her partnership interest ($30,000 basis in the equipment). Example 14 d. The partnership will take a carryover basis in all the assets it receives ($30,000 basis in cash, $40,000 basis in land, and $30,000 basis in equipment). p. 21-12 e. The partners’ outside bases in their partnership interests total $100,000: Carol’s basis of $70,000 plus Connie’s basis of $30,000. This is the same as the partnership’s basis in assets of $100,000 ($30,000 cash plus $40,000 land plus $30,000 equipment). p. 21-12 f. The partnership will ‘‘step into Connie’s shoes† in determining its depreciation expense. It will use the remaining depreciable life and the same depreciation rates Connie would have used. p. 21-12 29. Both partners are contributing assets valued at $100,000. One property has a built-in gain; the other has a built-in loss. Justin and Tiffany recognize no gain or loss on contribution of their respective properties to the partnership. Justin takes a substituted basis of $85,000 in his partnership interest ($20,000 cash plus $65,000 basis in land). The partnership takes a $65,000 carryover basis in the contributed land. The â€Å"built-in gain† on the land must be tracked and allocated to Justin if the property is ever sold at a gain [ §Ã‚  704(c)]. Section 721 applies to losses as well as gains and prevents Tiffany from recognizing the $25,000 loss on her contribution to the partnership. She will have a $125,000 basis in a partnership interest worth $100,000. Similarly, the partnership will have a $125,000 basis in assets valued at $100,000. The partnership will â€Å"step into Tiffany’s shoes† in determining depreciation deductions. As this is â€Å"built-in loss† property,  §Ã‚  704(c) applies, and amounts related to the built-in loss must be allocated to Tiffany. Depreciation must be allocated in accordance with Reg.  §Ã‚  1. 704-3 (not discussed in detail in this chapter). Basically, a large portion of the depreciation deductions would be allocated to Tiffany to reduce the difference between her basis and the fair market value of her partnership interest as qui ckly as possible. (If the property basis was less than its fair market value, depreciation would first be allocated to the other partner. )] pp. 21-10, 21-12, 21-13, 21-24, and Example 9 30. Tiffany has a taxable transaction when she sells the assets to a third party. She receives cash of $100,000 in exchange for assets with a basis of $125,000 and recognizes a $25,000 loss. (Based on the facts presented, the loss will likely be a  §Ã‚  1231 loss. ) When Tiffany contributes the $100,000 cash to the partnership, she recognizes no gain or loss and has a basis of $100,000 in her partnership interest. The partnership, of course, has a basis of $100,000 in the cash it receives. The partnership will need to use Tiffany’s $100,000 cash contribution, plus $10,000 of the cash Justin contributed to acquire new equivalent assets for $110,000. In this situation, the tax result to Tiffany is improved (she can recognize her $25,000 realized loss), but there is a $10,000 economic cost to the partnership when it acquires equivalent assets for $110,000 instead of $100,000. pp. 21-10, 21-12, 21-13, 21-24, and Example 8 31. a. None. Under  § 721, neither the partnership nor any of the partners recognize gain on contribution of property to a partnership in exchange for a partnership interest. b. $50,000. Ben’s basis in his partnership interest will equal the basis he held in the property he inherited from his father. The basis a beneficiary takes in property received from an estate generally equals the fair market value of the asset at the date of death or at the alternate valuation date (6 months later) if available and elected. p. 21-26 c. Beth will recognize $25,000 of ordinary income. The fair market value of Beth’s 50% partnership interest is $75,000. Since Beth will contribute only $50,000 of property, the difference between the amount contributed and the value of the interest will be treated as being for services rendered to the partnership. Services do not constitute ‘‘property’’ for purposes of  § 721 nonrecognition treatment. p. 21-11 d. Beth’s basis in her partnership interest will be $75,000 [$50,000 (cash contributed) + $25,000 (the amount of ordinary income recognized for services rendered to the partnership)]. Example 13 32. a. Assets Basis    FMV Cash $ 50,000 $ 50,000 Land50,00075,000 Land improvements 25,000 25,000 Total assets$125,000$150,000 Ben’s capital $ 50,000 $ 75,000 Beth’s capital 75,000 75,000 Total capital$125,000$150,000 Note that the partnership will capitalize the $25,000 deemed payment for Beth’s services, since the services relate to a capitalizable expenditure. The partnership will reflect this $25,000 in ‘‘cost of lots sold† as the development lots are sold. b. Beth could prepare a development plan and secure zoning permits before the partnership is formed. She could then contribute these plans and permits to the partnership in addition to the $50,000 cash. Since a completed plan would be considered â€Å"property,† no portion of her partnership interest would be received in exchange for services if this were done. The entire transaction would be considered under  § 721. p. 21-12 33. a. Under general guidelines, the $50,000 would be treated as a distribution, which, since it does not exceed Ben’s basis in his interest, would not be taxable. The distribution would reduce Ben’s basis in his partnership interest by $50,000. b. None. c. The partnership would take a basis of $50,000 in the land, Ben’s basis in the property at the time of the contribution. d. The IRS might assert that the contribution and distribution transactions were in effect a disguised sale of two-thirds ($50,000 distribution ? $75,000 fair market value) of the property contributed by Ben to the partnership. e. $16,667. Under disguised sale treatment, Ben will recognize gain on a sale of two-thirds of his interest in the land. He will be deemed to have received $50,000 in exchange for two-thirds of the land, with a basis of $33,333 ($50,000 basis ? 2/3). Total gain recognized, then, is $16,667. f. $66,667. The partnership will be deemed to have paid $50,000 for two-thirds of the land. The remaining one-third is deemed to be contributed to the partnership, and the partnership will take a carryover basis of $16,667 in this parcel. The partnership’s total basis is $66,667 ($50,000 + $16,667). Figure 21. 3 and Example 12 34. a. The partners’ initial bases in their partnership interests are the same amounts as their bases in the contributed property ( § 722). Rachel’s basis $360,000 Barry’s basis 600,000 b. The 2011 sale results in ordinary income of $170,000 to the partnership. 2011 sale: Selling price$530,000 Basis (360,000) Gain$170,000 The gain is ordinary income, since the land is held as inventory by the partnership. The land was a capital asset to Rachel, but no code provision allows treatment of the gain based on Rachel’s use rather than the partnership’s use. c. The 2012 sale results in a $100,000 capital loss and a $20,000 ordinary ( § 1231) loss. 2012 sale: Selling price$480,000 Basis (600,000) Loss ($120,000) As a sale of inventory (determined at the partnership level), the sale in 2012 of the land contributed by Barry would normally result in an ordinary ( §Ã‚  1231) loss. However,  §Ã‚  724 overrides the usual treatment. The character of the precontribution loss, instead, is determined based on the character of the property in Barry’s hands. This sale was within five years of the capital contribution date, so the loss is capital in nature to the extent of the built-in loss at the contribution date, which is: FMV at contribution$500,000 Basis (600,000) Capital loss ($100,000) The remaining $20,000 loss in 2012 is an ordinary ( § 1231) loss because the character of the post-contribution loss is based on the partnership’s ownership and use of the property as inventory. d. If the property Barry contributed was sold by the partnership in 2017, the entire $120,000 loss would be treated as an ordinary ( §Ã‚  1231) loss. A sale in 2017 would not be within five years of the contribution date, so the character of the loss would be determined solely by reference to the character of the asset to the partnership. Since the land is inventory to the partnership, the loss in 2017 would be ordinary. pp. 21-12, 21-13, and Examples 16 and 17 35. P5 Partnership, Ltd. has incurred costs for organizing ($10,000), starting the business ($60,000), transferring of property ($24,000), and securing investors ($1  million) for the partnership. The organizational costs are treated under  § 709. Under this section, the first $5,000 of such expenses are deducted (provid ed the total is less than $50,000); the remainder is amortized over 180 months. The startup costs are treated under  § 195. Under this section, also, the first $5,000 of such expenses are deducted, provided the total is less than $50,000. If costs exceed $50,000, the $5,000 deduction is phased out, dollar for dollar, by the amount of costs in excess of $50,000. When total costs equal or exceed $55,000 (as in this situation), no portion of the expense is currently deductible. Instead, the full amount is amortized over 180 months. The $24,000 transfer tax is treated as a cost of acquiring the land and is added to the partnership’s basis in the land. The $1 million of brokerage commissions is treated as a syndication cost of the partnership. Under  §709, these costs cannot be deducted. pp. 21-15 to 21-17 36. The SB Limited Liability Company must address the following issues in preparing its initial tax return: †¢ What year-end must the LLC use? Unless an election is made under  § 444, the LLC must use the year-end determined under the least aggregate deferral method. There is no majority member, and the principal members do not have the same year-end. Under the least aggregate deferral method, the LLC would use a July year-end since this would result in only a 5-month deferral of income to Block. Example 19 †¢ What method of accounting will the LLC use? Even though both members are Subchapter C corporations, the LLC may elect the cash method of accounting if average annual gross receipts are less than $5 million for the year. The LLC, then, could select either the cash, accrual, or a hybrid method of accounting. p. 21-17 †¢ How are the initial legal fees treated? Can the first $5,000 of organizational expenditures be immediately expensed and the balance amortized over a period of 180 months or more? Would any amounts be treated as startup expenditures under  § 195? p. 21-15 The members’ initial bases in their LLC interests must be determined. The bases will be the substituted basis of the assets contributed to the LLC ($650,000 for Block, and $550,000 for Strauss). Example 14 †¢ The LLC’s basis in th e property received from the members must be determined, and any cost recovery related to contributed property calculated. The LLC takes a basis of $650,000 in the equipment and steps into Block’s shoes in determining cost recovery allowances. Since the licenses and drawings are contributed rather than sold, the LLC takes a $0 basis in these assets, with no cost recovery possible. The LLC takes a $50,000 carryover basis in the land and a $500,000 basis in the cash. p. 21-12 The LLC must determine whether any portion of either of the LLC interests is issued in exchange for services. The equipment, cash, and land are considered â€Å"property† for purposes of  § 721. The building permits and architectural designs also are considered property under  § 721, even though they are intangible assets. Therefore, none of the LLC interests is issued in exchange for services. Example 13 †¢ Treatment of expenses incurred during the initial period of operations must be cons idered. The legal fees are organization costs and their tax treatment was previously noted. The construction costs must be capitalized until such time as the building is placed in service. The office expense may have to be capitalized under either (1)  § 195, if it is etermined that the business is still in the startup stage, or (2)  § 263A if it is determined the costs relate to â€Å"production† of the rental property. If neither of these provisions applies, the office expense is currently deductible. pp. 21-15 and 21-16 †¢ If the land is later sold, a portion of the gain must be allocated to Strauss, since the gain was â€Å"built-in† at the time the property was contributed. Note that if the equipment had been appreciated, depreciation allocations would have to take the precontribution gain into account. Allocation of precontribution deductions related to depreciable property are not covered in this text. p. 21-24 37. In 2008, 2009, and 2010, BR can use ei ther the cash, accrual, or a hybrid method of accounting. BR has at least one Subchapter C corporation as a partner, but BR’s average annual gross receipts did not exceed $5,000,000 in either 2008 or 2009. (BR’s average annual gross receipts were $4,600,000 for 2008 and $4,800,000 for 2009. ) In 2011, BR must change to the accrual method of accounting. BR has at least one Subchapter C corporation as a partner during that year, and BR’s average annual gross receipts for the preceding y How to cite South-Western Federal Taxation: Comprehensive Volume, Essay examples

Thursday, April 30, 2020

solution to the disadvantages of manual system Essays -

I really don't think that anyone in this world knows the real me. My closest friends know me better than anyone else, but I don't think I?ve ever let certain sides of me come out around anyone except myself. I keep some feelings hidden because no one would understand, and even if they did understand, there wouldn't be anything that anyone could do to make the feelings disappear. Worry about your character, not your reputation because your character is who you ` are & your reputation is what people think you are I'm not perfect, I never tried to be. I've made mistakes. I've taken the easy way out. I've lied to my friends. I've hidden the truth so many times from so many people. I've hurt people, and I've even done it on purpose. I've left people behind. I've spread rumors. I've said things that I didn't mean. I'm no better than anyone, anywhere. I'm human. I have faults, and I'm not afraid to admit that. I want to change, but I won't. Because that's what we do. That's what we've always done. We list our faults like a grocery list, and we move on, expecting everything to somehow change itself. It never will. I will never change. I will never be perfect. I will always make mistakes. I'll, more often than not, take the easy way out. I will lie, hide the truth, hurt people, leave people behind, spread rumors, and say things I don't mean for the rest of my life.--- jeneveve 'have you ever realized that when .. people say you?ve changed it?s just because you?ve stopped living your life ... their way Most people don't know who they are. That's why they lie. They're afraid someone else will figure it out before they do I?m nowhere near perfect I eat when I?m bored I fall for boys too easily I?m vulnerable to their lies I?m hoping that one day someone can get to know me without me getting into a long story I live by quotes that explain exactly what I?m going through I make excuses for everything in my life I?m not perfect and I?m glad because I think that would make me extremely boring Sorry I actually eat unlike some people...Sorry I can be myself around guys unlike some people... Sorry I like to have fun and I don?t care what people think about me... Sorry I am me But seriously how can you figure out what you?re made of if it's always easy. - Kris Langard I'm not always as confident as I seem ... there are many nights and many days when all I want is to be held. I love being held. Always. Sometimes I don't want to talk about what is bothering me ... sometimes I just want a hug ... someone who will let me cry. I like when boys cry in front of me -- when people aren't afraid to show what they're really feeling. I don't like when people run from their true feelings because it doesn't do anyone any good. I wear my heart on my sleeve, but I am not naive. I know what it feels like to be completely broken and I am all too familiar with what it means to be hurt. I know what it's like to see something funny and not laugh. I've been taken advantage of, used, and abused. My feelings have been blatantly disregarded. But I still believe that all people are good at heart ... and my trust in people has not diminished. To be completely honest, I hope it never does. Ever. "It hurts to look at yourself in the mirror and hate yourself, look into the mirror and wonder what ever happened to that smile that used to shine so bright. When you look at yourself, you see this version of "you" that your mind has created, someone that has become so distant and cold that nobody wants to be around her. Empty eyes. Fragile bones. The only thing you have left are the lies you tell yourself everyday to survive, lies that have become your painful reality, lies that will swallow you whole and crush your insides, lies that have turned you into someone you never wanted to be.." Congratulations! You're not perfect! It's ridiculous to want

Saturday, March 21, 2020

Siege of Boston in the American Revolution

Siege of Boston in the American Revolution The Siege of Boston occurred during the American Revolution and began April 19, 1775 and lasted until March 17, 1776. Commencing after the opening battles at  Lexington Concord,  the Siege of Boston saw the growing American army block the land approaches to Boston. During the course of the siege, the two sides clashed at the bloody Battle of Bunker Hill in June 1775. The stalemate around the city also saw the arrival of two commanders who would play a central role in the conflict over the next three years:  General George Washington  and  Major General William Howe. As the fall and winter progressed, neither side proved able to gain an advantage. This changed in early 1776 when artillery captured at Fort Ticonderoga arrived in the American lines. Mounted on Dorchester Heights, the guns compelled Howe to abandon the city. Background In the wake of the Battles of Lexington Concord on April 19, 1775, American colonial forces continued to attack British troops as they attempted to withdraw back to Boston. Though aided by reinforcements led by Brigadier General Hugh Percy, the column continued to take casualties with particularly intense fighting occurring around Menotomy and Cambridge.  Finally reaching the safety of Charlestown late in the afternoon, the British were able to gain a respite. While the British consolidated their position and recovered from the days fighting, militia units from across New England began arriving on the outskirts of Boston. Armies Commanders Americans General George WashingtonMajor General Artemas Wardup to 16,000 men British Lieutenant General Thomas GageMajor General William Howeup to 11,000 men Under Siege By morning, around 15,000 American militiamen were in place outside of the city. Initially guided by Brigadier General William Heath of the Massachusetts militia, he passed command to General Artemas Ward late on the 20th. As the American army was effectively a collection of militias, Wards control was nominal, but he succeeded in establishing a loose siege line running from Chelsea around the city to Roxbury. Emphasis was placed on blocking Boston and Charlestown Necks. Across the lines, the British commander, Lieutenant General Thomas Gage, elected not impose martial law and instead worked with the citys leaders to have private weapons surrendered in exchange for allowing those residents who desired to leave Boston to depart. The Noose Tightens Over the next several days, Wards forces were augmented by new arrivals from Connecticut, Rhode Island, and New Hampshire. With these troops came permission from the provisional governments of New Hampshire and Connecticut for Ward to assume command over their men. In Boston, Gage was surprised by the size and perseverance of the American forces and stated, In all their wars against the French they never showed such conduct, attention, and perseverance as they do now. In response, he began fortifying parts of the city against attack. Consolidating his forces in the city proper, Gage withdrew his men from Charlestown and erected defenses across Boston Neck. Traffic in and out of the city was briefly restricted before both sides came to an informal agreement allowing civilians to pass as long as they were unarmed. Though deprived of access to the surrounding countryside, the harbor remained open and ships of the Royal Navy, under Vice Admiral Samuel Graves, were able to supply the city. Though Graves efforts were effective, attacks by American privateers led prices for food and other necessities to rise dramatically. Lacking artillery to break the stalemate, the Massachusetts Provincial Congress dispatched Colonel Benedict Arnold to seize the guns at Fort Ticonderoga. Joining with Colonel Ethan Allens Green Mountain Boys, Arnold captured the fort on May 10. Later that month and into early June, American and British forces skirmished as Gages men attempted to capture hay and livestock from the outer islands of Boston Harbor (Map). Battle of Bunker Hill On May 25, HMS Cerberus arrived at Boston carrying Major Generals William Howe, Henry Clinton, and John Burgoyne. As the garrison had been reinforced to around 6,000 men, the new arrivals advocated for breaking out of the city and seizing Bunker Hill, above Charlestown, and Dorchester Heights south of the city. The British commanders intended to implement their plan on June 18. Learning of the British plans on June 15, the Americans quickly moved to occupy both locations. To the north, Colonel William Prescott and 1,200 men marched onto the Charlestown Peninsula on the evening of June 16.  After some debate among his subordinates, Prescott directed that a redoubt be constructed on Breeds Hill rather than Bunker Hill as originally intended. Work commenced and continued through the night with Prescott also ordering a breastwork to be built extending down the hill to the northeast. Spotting the Americans works the next morning, British warships opened fire with little effect. In Boston, Gage met with his commanders to discuss options. After taking six hours to organize an assault force, Howe led British forces over to Charlestown and attacked on the afternoon of June 17. Repelling two large British assaults, Prescotts men stood firm and were only forced to retreat when they ran out of ammunition. In the fighting, Howes troops suffered over 1,000 casualties while the Americans sustained around 450. The high cost of victory at the Battle of Bunker Hill would influence British command decisions for the remainder of the campaign. Having taken the heights, the British began work to fortify Charlestown Neck to prevent another American incursion. Building an Army While events were unfolding in Boston, the Continental Congress in Philadelphia created the Continental Army on June 14 and appointed George Washington as commander-in-chief the following day. Riding north to take command, Washington arrived outside Boston on July 3. Establishing his headquarters in Cambridge, he began molding the masses of colonial troops into an army. Creating badges of rank and uniform codes, Washington also began creating a logistical network to support his men. In an attempt to bring structure to the army, he divided it into three wings each led by a major general. The left wing, led by Major General Charles Lee was tasked with guarding the exits from Charlestown, while Major General Israel Putnams center wing was established near Cambridge. The right wing at Roxbury, led by Major General Artemas Ward, was the largest and was to cover Boston Neck as well as Dorchester Heights to the east. Through the summer, Washington worked to expand and reinforce the American lines. He was supported by the arrival of riflemen from Pennsylvania, Maryland, and Virginia. Possessing accurate, long range weapons, these sharpshooters were employed in harassing the British lines. Next Steps On the night of August 30, British forces launched a raid against Roxbury, while American troops successfully destroyed the lighthouse on Lighthouse Island. Learning in September that the British did not intend to attack until reinforced, Washington dispatched 1,100 men under Arnold to conduct an invasion of Canada. He also began planning for an amphibious assault against the city as he feared his army would break up with the arrival of winter. After discussions with his senior commanders, Washington agreed to postpone the attack. As the stalemate pressed on, the British continued local raiding for food and stores. In November, Washington was presented a plan by Henry Knox for transporting Ticonderogas guns to Boston. Impressed, he appointed Knox a colonel and sent him to the fort. On November 29, an armed American ship succeeded in capturing the British brigantine Nancy outside of Boston Harbor. Loaded with munitions, it provided Washington with much needed gunpowder and arms. In Boston, the situation for the British changed in October when Gage was relieved in favor of Howe. Though reinforced to around 11,000 men, he was chronically short on supplies. The Siege Ends As winter set in, Washingtons fears began to come true as his army was reduced to around 9,000 through desertions and expiring enlistments. His situation improved on January 26, 1776 when Knox arrived in Cambridge with 59 guns from Ticonderoga. Approaching his commanders in February, Washington proposed an attack on the city by moving over the frozen Back Bay, but was instead convinced to wait. Instead, he formulated a plan to drive the British from the city by emplacing guns on Dorchester Heights. Assigning several of Knoxs guns to Cambridge and Roxbury, Washington began a diversionary bombardment of the British lines on the night of March 2. On the night of March 4/5, American troops moved guns to Dorchester Heights from which they could strike the city and the British ships in the harbor. Seeing the American fortifications on the heights in the morning, Howe initially made plans for assaulting the position. This was prevented by a snowstorm late in the day. Unable to attack, Howe reconsidered his plan and elected to withdraw rather than have a repeat of Bunker Hill. The British Depart On March 8, Washington received word that the British intended to evacuate and would not burn the city if allowed to leave unmolested. Though he did not formally respond, Washington agreed to the terms and British began embarking along with numerous Boston Loyalists. On March 17, the British departed for Halifax, Nova Scotia and American forces entered the city. Having been taken after an eleven-month siege, Boston remained in American hands for the remainder of the war.

Wednesday, March 4, 2020

Use of Pastiche in English Prose

Use of Pastiche in English Prose A text that borrows or imitates the style, words, or ideas of other writers. Unlike a parody, which aims for a comic or satiric effect, a pastiche is often intended as a compliment (or an homage) to the original writer(s)though it may just be a hodgepodge of borrowed words and ideas. Examples and Observations: The pastiche prose form openly mimes the content and mannerisms of another written work. Its a respectful, if often jocular, an homage to the work that inspired it. (Its literary cousin is the parody, but that imitation subtly or savagely satirizes its source material.) The pastiche implicitly says, I appreciate this author, the characters, and the fictive world . . . and my imitation is sincere flattery.The affection for Sir Arthur Conan Doyle and his immortal Sherlock Holmes is evident in August Derleths stories about brilliant, deerstalker-wearing Solar Pons of 7B Praed St.(Mort Castle, Write Like Poe. The Complete Handbook Of Novel Writing, 2nd ed. Writers Digest Books, 2010)The secret mechanism of a pastiche is the fact that a style is not just a unique set of linguistic operations: a style is not just a prose style. A style is also a quality of vision. It is also its subject matter. A pastiche transfers the prose style to a new content (while parody transfers the prose style to an inadmissible and scandalous content): it is, therefore, a way of testing out the limits of a style.(Adam Thirlwell, The Delighted States. Farrar, Straus and Giroux, 2007) Parody and Pastiche in The SimpsonsParody attacks a particular text or genre, making fun of how that text or genre operates. Pastiche merely imitates or repeats for mildly ironic amusement, whereas parody is actively critical. For instance, when an episode of The Simpsons loosely follows the plot of Citizen Kane (rendering Mr. Burns as Kane), no real critique is offered of Orson Welless masterpiece, making this pastiche. Yet on a weekly basis, The Simpsons plays with generic conventions of the traditional family sitcom. It also mocks forms of advertising and . . . it occasionally lambastes the form and format of news, all with critical intent, thereby making such instances bona fide parody.(Jonathan Gray, Jeffrey P. Jones, and Ethan Thompson, The State of Satire, the Satire of the State. Satire TV: Politics and Comedy in the Post-Network Era. New York University Press, 2009)Pastiche in Green Days American Idiot (Musical)The sheer volume of the stage band’s music and the frenet ic rush of action provide constant energy. But tunes recalling the 1950s pastiche of The Rocky Horror Picture Show or, during We’re Coming Home Again, the Phil Spectoresque Springsteen of Born to Run, have few punk credentials. The indulgent-youths versus dutiful-wives combat of Too Much Too Soon also shows how much [Bilie Joe] Armstrong’s characters are [Jack] Kerouac boys and girls at base, American idiots and ennui unchanged.(Nick Hasted, Green Day’s American Idiot, Hammersmith Apollo, London. The Independent, December 5, 2012) Pastiche in Peter PanThe apparent contradiction whereby war converts into a game is weirdly captured in Baden-Powells favorite play, J.M. Barries Peter Pan (1904), which he saw many times in the years he was gestating Scouting for Boys. In the Neverland of the play, Peters boys, the pirates, and the Indians relentlessly track after one another in a literal vicious circle that, though it is on one level all burlesque, an excessive late Imperial pastiche of the commonplaces of childrens fiction, is also deadly seriousas the final carnage on Captain Hooks ship vividly dramatizes.(Elleke Boehmer, introduction to Scouting for Boys: A Handbook for Instruction in Good Citizenship by Robert Baden-Powell, 1908; Rpt. 2004)Samuel Becketts Use of Pastiche[Samuel] Becketts cutting and pasting his reading onto his own stock of prose produced a discourse that Giles Deleuze might call rhizomatic or a technique Frederic Jameson might call pastiche. That is, these early works are finally assemblages, intertextual layerings, palimpsests, the effect of which is to produce (if not reproduce) a multiplicity of meanings in a manner that will come to be thought Postmodern in the second half of the twentieth century. . . .Postmodern pastiche would suggest that the only style possible in contemporary culture is travesty or mimicry of past stylesquite the opposite of what Beckett was developing. Intertext or assemblage or pastiche allowed Beckett to assault the idea of style and so (or thereby) develop his own . . ..(S.E. Gontarski, Style and the Man: Samuel Beckett and the Art of Pastiche. Samuel Beckett Today: Pastiches, Parodies Other Imitations, ed. by Marius Buning, Matthijs Engelberts, and Sjef Houppermans. Rodopi, 2002) Fredric Jameson on PasticheHence, once again, pastiche: in a world in which stylistic innovation is no longer possible, all that is left is to imitate dead styles, to speak through the masks and with the voices of the styles in the imaginary museum. But this means that contemporary or postmodernist art is going to be about art itself in a new kind of way; even more, it means that one of its essential messages will involve the necessary failure of art and the aesthetic, the failure of the new, the imprisonment in the past.(Fredric Jameson, Postmodernism and Consumer Society. The Cultural Turn: Selected Writings on the Postmodern, 1983-1998. Verso, 1998)

Monday, February 17, 2020

MIH514 - Cross-Cultural Perspectives Module 2 - SLP Essay

MIH514 - Cross-Cultural Perspectives Module 2 - SLP - Essay Example They are able to guide proceedings in the household, although in the present set up, with wives also playing more important earning roles in the household, the overall dominance of the male has dramatically reduced in modern times. However, according to South Korean culture, the traditional dictums of male supremacy is slowly declining, especially when women are as adept in seeking and pursing gainful employment for the upkeep and maintenance of the family. While traditionally, it has been the eldest male who is bestowed the honor of being the earning head of the family and controls the purse strings, in the modern changing context, this has become more flexible and the role of the fairer gender is also assuming greater importance. The major goal, obviously, is the sustenance of family values and its enrichment. Besides, it is also necessary to take good care of the family bonding and economic growth and development. There is need to take an overall view of family goals and priorities in terms of education, heath care and seeking interventions that go to improve living standards of families in South Korean context. This country has been endowed with very hardworking people with strong character and valued principles in life, and has been able to hold its own, despite being split from North Korea. â€Å"Koreas population is one of the most ethnically and linguistically homogenous in the world. Except for a small Chinese community (about 20,000), virtually all Koreans share a common cultural and linguistic heritage. With 48.6 million people, South Korea has one of the worlds highest population densities. Major population centers are located in the northwest, southeast, and in the plains south of the Seoul-Incheon area.† (Background note: South Korea, 2009). The development tasks that have been undertaken by South Korea at grassroots individual, family and community levels are indeed exemplary. Moreso, in the