Your clients, Grayson Investments, Inc. (Ana Marks, President), and Blake Caldwell, each contributed $200,000 of cash to form the Realty Management Partnership, a limited partnership. Grayson is the general partner, and Blake is the limited partner. The partnership used the $400,000 cash to make a down payment on a building. The rest of the building’s $4,000,000 purchase price was financed with an interest-only nonrecourse loan of $3,600,000, which was obtained from an independent third-party bank.
The partnership allocates all partnership items equally between the partners except for the MACRS deductions and building maintenance, which are allocated 70% to Blake and 30% to Grayson. The partnership wants to satisfy the “economic effect” requirements of Reg. §§ 1.704–1 and 1.704–2 and will reallocate MACRS, if necessary, to satisfy the requirements of the Regulations.
Under the partnership agreement, liquidation distributions will be paid in proportion to the partners’ positive capital account balances. Capital accounts are maintained as required in the Regulations. Grayson Investments has an unlimited obligation to restore its capital account, while Blake is subject to a qualified income offset provision.
Assume that all partnership items, except for MACRS, will net to zero throughout the first three years of the partnership operations. Also assume that each year’s MACRS deduction will be $200,000 (to simplify the calculations).
Draft a letter to the partnership, evaluating the allocation of MACRS in each of the three years under Reg. §§ 1.704–1 and –2. The partnership’s address is 53 East Marsh Ave., Smyrna, GA 30082. Do not address the “substantial” test.
- Perform and identify each step separately 2-3a through 2-3f.
- In step 2-3b, Refining the Problem, list all of the issues you intend to research.
- In step 2-3c prepare a list of “Key Words” derived from the issues to guide your research.
- In step 2-3d list each for the tax resources you found utilizing “Key Words” from step 3 preparing a brief outline of what the resource conveyed and strike out the resources that do not apply to your problem upon further review.
- In step 2-3e Support your solution or alternative solutions from your research.
- Prepare your Tax File Memorandum, Exhibit 2.9,, from information contained in steps 2-3a through 2-3e.
- In step 2-3f Prepare a Client Letter, Exhibit 2.10 to communicate your research to the client.
A bureaucracy is a model of organization centered on guidelines, chain of command, impersonality and labor division. It has been the leading system of organization for more than a century. Grey argues that Post-bureaucracy is built on confidence, enablement, personal conduct as well as collective responsibility(2006). But it carries its own difficulties in control loss, inequity as well as risk. The generation Facebook expect the work’s social environment to be a reflection of the social content in the web. The author says that they will utilize the 12 realities so as to determine whether a company is with it. The first reality that the author states is that all ideas on the web compete on an equal footing. In the Web, ideas ought to compete sovereign from the individual who came up with them. Every idea has merit and has to be treated in an equal way. (Hamel, 2016). Another reality which the author talks about is that contribution counts for more than credentials. It’s what one is capable of and the actions they take, not their school of education or what they are qualified to do. What matters most is what an individual contributes but not their credentials (Hamel, 2016). The third reality states that hierarchies are built bottom up. It’s insufficient to have a regular managerial structure, it is also essential to let fresh groups to form, in a natural way just as it happens on the Web. There is a strong requirement for self-managed teams with this group. In all online Web forums, there are always the people who normally get more attention and respect from people than others; they as a result have more influence whenever they say anything. It is worth noting that these individuals do not get any sort of appointments from any superior persons. Hamel (2016) says that it is instead their influence which is comes out freely from the approval they get from their peers. Authority on the Web never trickles downward, but upwards. The author says that Leaders serve rather than preside. A commanding style as well as controlling people online will not work at all. This Generation is wired to be imaginative, to function as groups, and they are set up in a way to repel authoritative control. Servant leadership; one makes sure that the individuals involved have everything needed so as to do their work. This is a usually superior form in most cases.>GET ANSWER