- 17 - • All partners who originally assumed personal liability for a portion of the partnership debt during the first year of the partnership -- whether they are now determined to be active or inactive partners -- will be assigned a share of the lower amount of recognized partnership debt described above. Each partner’s share will be the exact same percentage as his/her share of the partnership debt originally assumed. * * * * * * * • Inactive partners are deemed to have liquidated their respective partnership interest when they abandon it, according to the following guidelines: " The amount realized by partners on the liquidation of their partnership interest will be the amount of the assumed liability for which they remained liable when they abandoned their interest in the partnership. This amount is the partner’s share of the lower recognized partnership debt described above. " The deemed liquidation of partnership interest by inactive partners will occur on December 31 of the year they become inactive, as described above. • In computing “At Risk,” active partners are entitled to include their prorated share of partnership debt which was previously attributable to inactive partners for purposes of “At Risk” and basis. Active partners assume this additional debt on the date an inactive partner is deemed to have liquidated his/her partnership interest, as described in the immediately preceding paragraph. • Profits, losses and credits -- after considering Mr. Hoyt’s share -- are allocated strictly on the basis of capital account. This means that each partner’s interest in the credits, profits and/or loss is calculated annually by comparing the partner’s capital account to the aggregate of the capital accounts of all partners in the partnership.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011