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Carmelo Jones is one of the two general partners in The house Warehouse, an accrual method...

Carmelo Jones is one of the two general partners in The house Warehouse, an accrual method (for both financial and tax reporting purposes) limited partnership which has over 3,000 limited partners all of which are passive investors. Carmelo wants to retire and therefore, wants out of the partnership. He currently owns a 12% interest in the limited partnership with an outside basis of $425,000. In exchange for his partnership interest, the other general partner offers him: $10,000 cash, internally generated unrealized receivables, inventory and the company-owned Mercedes. The receivables have a tax basis of $0 and a fair market value of $150,000. The inventory has a tax basis of $90,000 and a fair value of $220,000. The Mercedes has a tax basis of $65,000 and a fair value of 45,000. What would be the recognized gain/loss to Peter if he accepts this deal for a liquidating distribution? Assume the departing partner is an individual and not organized as a corporation.

a. The departing partner will have a $280,000 recognized ordinary gain on this arrangement and a $20,000 capital loss assuming no depreciation recapture for the Mercedes.

b. The departing partner will have no recognized capital gain or loss and no recognized ordinary gain or loss on this liquidating distribution.

c. The departing partner will have a $130,000 recognized capital loss and a 50,000 recognized ordinary gain on this arrangement.

d. None of the above

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