Whitman & Ransom, Maged F. Riad, Tax Matters Partner - Page 7

                                          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...)           





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