Hermine is a partner with a capital and profits interest in…
Hermine is a partner with a capital and profits interest in Fringetree, a general partnership. On January 1, Fringetree distributes the following assets to Hermine in complete liquidation of her interest (a proportionate liquidating distribution): Fair value Adjusted basis Cash $60,000 $60,000 Hot Asset $10,000 $0 Other Asset A $40,000 $30,000 Other Asset B $160,000 $90,000 Total $270,000 $180,000 The partnership has no liabilities. (1) If Hermine’s basis in her partnership interest was $80,000, what is Hermine’s beginning basis in Other Asset A after the distribution? (2) If Hermine’s basis in her partnership interest was instead $360,000 (and not $80,000), what is Hermine’s beginning basis in Other Asset A after the distribution? (3) Assume Fringetree held Other Asset A for two years prior to the distribution. What is Hermine’s holding period in this distributed asset? (4) Assume the distributed Hot Asset is inventory and that Hermine sells it for more than her basis three years after the distribution. What is the character of Hermine’s gain if she does not hold the property for sale as inventory?