Greg, Alex, and Tom formed a general partnership in 2000 which they call Green Mountain Partners

Greg, Alex, and Tom formed a general partnership in 2000 which they call Green Mountain Partners. Green Mountain Partners presently owns a bed and breakfast inn located in Quechee, Vermont.  The property consists of a twenty-bedroom inn and spa complex, surrounded by twenty five acres of wooded property with walking and riding trails.  Greg and Alex each hold a 30 percent capital and profits interest in the partnership, while Tom holds a 40 percent capital and profits interest.

Greg holds an adjacent 30-acre piece of undeveloped land which he purchased in 1985 for 

investment purposes for $350,000.  The property presently has no mortgage or other encumbrances on it.  Current fair market value of the property is approximately $2,100,000.

Greg, Alex, and Tom would like to subdivide Greg's adjacent property and build an active retirement community consisting of 80 single-family homes, a riding stable, indoor swimming pool and gym, plus a recreational center.  They estimate that land development and building costs for each home will average about $275,000 each, and can be marketed for approximately $525,000 each.

Green Mountain Partners do not anticipate any problems with bank financing on this project.  They come to you as their CPA and financial advisor, and ask the following:

1.    If Greg contributedthe land to the partnership, Green Mountain Partners would hold the land at what basis?  Determine the character and estimate the amount of income/gain to Greg and his partners under this scenario.

2.    If Greg soldthe land to the partnership, Green Mountain Partners would hold the land at what basis?  Determine the character and estimate the amount of income/gain to Greg and his partners under this scenario.

o  Use an Excel Spreadsheet to calculate basis and earnings allocation to the partners under each of the two scenarios above.

o  Which scenario would you advise Greg to use if he wants to defer his tax liability?

o  Which scenario would you advise Greg to use if he needs cash for personal needs now?

Begin your research with Chapter 9 - Formation of Partnerships regarding contributed property. The question I am asking you to address is whether the client should sell his property to the partnership or whether he should contribute the property. Look at the area addressing built in gain. Think about whether he has held the property as investment property or as inventory. Then think about whether the partnership will hold the property for investment purposes or inventory. Look at the very different classification of income derived from the sale of investment property versus inventory.