Reference no: EM131632438

Question - A and B form a limited partnership. A is a limited partner and B is the general partner. A contributes $360 and B contributes $40 to the partnership. The partnership agreement contains a minimum gain chargeback provision and complies with the qualified income offset rules of the I.R.C. Section 704(b) Regulations. Neither partner has a deficit restoration obligation. The partnership agreement further provides that all losses will be allocated 90% to A and 10% to B and that all income will be allocated in the same manner until income allocations equal previous loss allocations. Thereafter, income and losses will be allocated 50% to A and 50% to B. The partnership borrows $1,600 from an unrelated commercial lender on a nonrecourse basis and purchases depreciable property for $2,000. Only interest on the loan is due for the first five years the debt is outstanding. The partnership breaks even in its first three years of operation except for depreciation deductions of $400 per year, and thus generates a loss each of its first three years of $400. Assume that on January 1 of year 4, the partnership sells the property for $2,400. Assume that aside from this sale, the partnership breaks even on operations in year four. For years 1-4, provide the partners' capital accounts and shares of minimum gain.