Course: Partnership Taxation: TAX-504-2108

Assignment: Assignment 2 (based on class 6)

The ABC equal limited partnership (in which A is a general partner and B and C are limited partners) purchased an apartment building for $540,000, paying $90,000 of cash (contributed equally by the partners in the partnership) and financing the balance with a $450,000 nonrecourse loan secured by the building.
Assume that A, B, and C are all unrelated and that the partnership holds no other assets. To what extent are each of the partners at risk (i.e., compute each partner’s “at-risk basis”) if the loan is:

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(a) From a commercial bank in which none of the parties owns an interest.

(b) From the seller of the apartment complex. See Section 465(b)(6)(A).

(c) From B’s brother, who is in the money lending business and makes the loan at a rate of interest 25% below comparable rates charged to unrelated borrowers. Remember, each partner applies the at-risk rules individually.

(d) The same as (c), above, except the loan is at regular commercial rates of interest. See Section 465(b)(6)(D)(ii).


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