Question

Lance contributed investment property worth $605,000, purchased three years ago for $300,000 cash, to Cloud Peak...

Lance contributed investment property worth $605,000, purchased three years ago for $300,000 cash, to Cloud Peak LLC in exchange for an 90 percent profits and capital interest in the LLC. Cloud Peak owes $305,000 to its suppliers but has no other debts.

a. What is Lance’s tax basis in his LLC interest?

b. What is Lance’s holding period in his interest?

c. What is Cloud Peak’s basis in the contributed property?

d. What is Cloud Peak’s holding period in the contributed property?

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Answer #1

a. Lance’s tax basis in his LLC interest =(90% x $305000) + $300000 = $574500. Because LLC general debt obligations are treated as non recourse debt.

b. Lance’s holding period in his interest = 3 years. Beacause Lance contributed a capital asset .

c. Cloud Peak’s holding period in the contributed property = $300000. Because the LLC takes a carryover basis in the contributed property.

d. Cloud Peak’s holding period in the contributed property = 3 Years. Because the LLC receives Lance's holding period in the contributed property.

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