7 balance in his capital account: Partner Capital Account Balance Parson ($30,823) Handler (186,739) Hahn (96,351) Sargent (85,470) Tilton (46,138) The total deficit came to $445,521. On its 1996 partnership return, W&R elected the cash method of accounting for tax purposes. The partnership return’s Schedule M-2, Analysis of Partners’ Capital Accounts, reported that each withdrawing partner contributed capital equal to the amount of the withdrawing partner’s negative capital account balance resulting in total capital contributed of $445,522.4 The amount reported as capital contributed in 1996 for each withdrawing partner zeroed out each withdrawing partner’s negative capital account balance. W&R reported on its 1996 partnership return total income of $678,711 and claimed a deduction of $456,522 as “Guaranteed payments to partners”.5 W&R issued to each withdrawing partner a 4 The $1 difference between the capital account balances shown on the chart attached and that claimed on Schedule M-2 will be attributed to rounding. 5 In addition to bringing the negative capital accounts of the withdrawing partners to zero which made up $445,522, of the claimed guaranteed payments, W&R actually paid Allen $1,000 for services rendered and $10,000 to Morse for his services with regard to the termination and liquidation of W&R’s retirement plans. The payments to Allen and Morse have been conceded by (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011