User talk:LSC CPA

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Like Kind Exchange

Linda, Thank You for the personal response! - I'm hoping to try to work thru mine tomorrow; hope it's not as crazy as today has been. I'll let you know if I come up with anything better. And I agree, (1)don't need to be slammed in the 'public' forum and (2) sometimes, we just have to make things work. Hope I can be of assistance to you in the future. Belle 18:41, 25 February 2008 (CST)

Incorporating in Illinois

Hi, Linda. My name is Jim Hill & like you I work for a CPA firm & do tax work on the side. I've done dozens of incorporations. If you would like some more info, just call me.

Baloun & Co: 847-991-1111 Home: 847-214-9062 Cell: 847-890-5786

Marcilio 08:10, 16 July 2008 (CDT)


I came across the following example in Kleinrock as I was trying to research our similar situations. I'm not sure if this will help you. I'm not sure how this all gets implemented. If this helps, and you can determine how to implement, will you let me know?



EXAMPLE: Maggie, a solvent individual, owns a 50 percent interest in a partnership that owns land on which it operates a parking lot and a 25 percent interest in a second partnership that owns a shopping mall. The parking lot partnership's land has a basis and a value of $200,000, and it secures a qualified real property business indebtedness having an outstanding balance of $300,000. The shopping mall partnership's depreciable basis in its mall is $400,000, and it owns the mall free and clear. If the parking lot partnership negotiates a $100,000 reduction from its lender (which reduction satisfies the fair market value limitation as applied to the partnership), Maggie's 50 percent share of the $100,000 of discharge income will be $50,000 and will constitute qualified real property business indebtedness income to her. Although the parking lot partnership has no depreciable basis for purposes of the aggregate depreciable basis limitation, Maggie has sufficient basis, $100,000, in her allocable share of the shopping mall partnership's depreciable real property to absorb the $50,000 of qualified real property business indebtedness discharge income from the parking lot partnership. Accordingly, Maggie may elect to exclude the $50,000 from her income, provided a $50,000 reduction is made in her $100,000 basis of her shopping mall partnership interest and in her $100,000 allocable share of the partnership's depreciable mall basis.

PRACTICE TIP: A consenting partnership must include with the Form 1065, U.S. Partnership Return of Income, for the taxable year following the year that ends with or within the taxable year the taxpayer excludes COD income from gross income under Code Section 108(a), and must provide to the taxpayer on or before the due date of the taxpayer's return (including extensions) for the taxable year in which the taxpayer excludes COD income from gross income, a statement that: (1) Contains the name, address, and taxpayer identification number of the partnership; and (2) states the amount of the reduction of the partner's proportionate interest in the adjusted bases of the partnership's depreciable property or depreciable real property, whichever is applicable. For tax years beginning after 2002, taxpayers must retain the statements in their records. For earlier tax years, the statements must be attached to a taxpayer's timely filed (including extensions) federal income tax return for the taxable year in which the taxpayer has COD income that is excluded from gross income. Reg. Section 1.1017-1(g)(2)(iii)(B).

Go to consent to reduce partnership basis in partnership property.

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