- 23 - were included in the reported amount realized of $4.8 million, and then distributed to petitioner. On the Coastal side of the transaction, there's a disparity in the book and tax treatments of petitioner's participation in Coastal: Coastal recorded on its books a contribution to capital by petitioner in the amount of $700,000; on Coastal's tax balance sheet reconciliation of partners' capital accounts, petitioner is shown as having made no capital contribution. This disparity is reflected in Coastal's book and tax accounting for the receipt of the Mall, which was booked at a value that exceeds its tax basis by approximately the same amount as the equivalent amounts of the credits and petitioner's capital contribution. It's the tax treatment of the credits, at both the Pecaris partnership and partner levels, over which the parties part company. A. Amount of Pecaris Gain 1(a) Amount Realized Having opened up the transaction for review, we must first determine the amount of the Pecaris gain on its sale of the Mall to Coastal. Under section 1001(a) "The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis" of the property. Under section 1001(b), "The amount realized * * * shall be thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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