TAX 9900 Lecture Notes - Lecture 32: Cash Flow

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31 Mar 2020
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On january 1, 2015, bernie and derek form a limited partnership to acquire and operate an office building. Bernie, the general partner, contributes for a 10% interest, and derek, the limited partner, contributes for a 90% interest. Derek has no deficit restoration obligation, but bernie, as the general partner, does have a deficit restoration obligation. A bank gives the partnership a nonrecourse mortgage of in connection with the partnership"s acquisition of the office building for . The mortgage is interest only for five years. The building is depreciable over a ten-year period on a straight-line basis. The partnership agreement satisfies the alternative test for economic effect in treas. 1(b)(2)(ii)(d) and contains a minimum gain chargeback provision. The partnership agreement provides that, subject to the minimum gain chargeback provision, all income and loss other than nonrecourse deductions (as defined in.

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