Last year, Abhinav and Bilguutei formed ABC, LLC, a car dealership in Chicago. This year, Abhinav and Bilguutei realized they needed an advertising expert so they offered Connor, a marketing expert, a one-third profits interest in their partnership for contributing his expert services and Connor accepted the offer. The value of the LLC's capital equals $180,000 when Connor receives his one-third capital interest. If ABC's profit is $30,000 and no distributions are made to owners next year, which of the following is CORRECT?

Question

BlackTom AI · Accepted Answer

This question involves the tax treatment when a new partner is admitted to a partnership in exchange for services, and then examines how profits are allocated in the following year.
Option 1: "Connor reports $60,000 of ordinary income in the current year." When a person is compensated for services by receiving a partnership interest, the service provider must recognize ordinary income equal to the fair market value of the partnership interest at the grant date. Here, Connor received a one-third interest valued at $60,000 (1/3 of the $180,000 capital value). Therefore, Connor would recognize $60,000 of ordinary income in the current year as a result of the services provided in exchange for the partnership interest. This is a correct description of the tax rule for service-contributions to a partnership.
Option 2: "Abhinav, Bilguutei, and Connor receive an ordinary deduction of $20,000 in the current year." Generally, a partnership deducts ordinary business expenses paid or incurred. However, the formation of a new partner in exchange for services does not create an ordinary deduction of $20,000 for the partners. Instead, the service value is recognized by the service provider as ordinary income, not as a deduction to the other partners. The $20,000 figure does not align with the described scenario and is not supported by the usual tax treatment of such an admission.
Option 3: "Abhinav and Bilguutei each receive an ordinary deduction of $30,000 in the current year." Similar to Option 2, there is no basis for a deduction of $30,000 to the existing partners arising from admitting a new partner in exchange for services. The tax impact is on the service provider (Connor) recognizing ordinary income, while the partnership increases its basis by the amount of the service value. A deduction to Abhinav and Bilguutei in this amount would misstate the tax treatment.
Option 4: "Next year, Connor will be allocated $10,000 of the undistributed profits for his one-third LLC interest." In a partnership, allocations of profits are based on the partnership agreement and the partners’ ownership interests, and they occur regardless of whether cash distributions are made. With a $30,000 profit and Connor owning one-third, Connor would be allocated $10,000 for the next year. However, the wording here refers to "undistributed profits" which is a bit unusual, since distributive shares are allocated to partners whether or not distributions are made. Nonetheless, the allocation of $10,000 to Connor reflects his one-third share of the profit for the year, and this is a consistent treatment with partnership allocations when profits are not distributed.

In summary, option analyses show that Option 1 correctly reflects the initial ordinary income recognition by Connor due to receiving a partnership interest for services, while Options 2 and 3 misstate the tax treatment for the other partners, and Option 4 aligns with the basic profit-sharing mechanics but uses nonstandard phrasing. The question’s correct choice focuses on the service-based income recognition and the subsequent profit allocation to Connor in the absence of distributions.

SU25-BL-BUS-A329-2695 Quiz 17

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