Bakhsh letter Free Essays

As a global pilot with 11 years experience, I would make an extraordinary expansion to your flight staff. I am prepared and guaranteed to fly by both the Unites States’ Federal Aviation organization and the Saudi Arabian General Authority of Civil Aviation, having concentrated on planes in both of the nations. Since I am conversant in both English and Arabic, I am an incredible resource for any organization with trips into Northern Africa. We will compose a custom article test on Bakhsh letter or on the other hand any comparable theme just for you Request Now From my encased resume, you will take note of that I have a solid record of achievement during my time as a pilot. I started as first official on a Boeing 737 and climb to my last situation as first official on a Boeing 777 preceding being made commander of a McDonnell-Douglas 90. From that point forward, I have been again advanced and at present fill in as Captain of an Embracer E170. Notwithstanding my flight understanding, I have had worldwide pilot instructional classes with Boeing, in Seattle, WA, USA, and Embracer in Zurich, Switzerland. I am a dependable Captain, taking the most extreme consideration to guarantee that my airplane is very much thought about and my travelers show up securely at their goal. Much obliged to you for setting aside the effort to survey my resume and qualification. I anticipate the chance to meet with you to talk about how I might be a resource for your organization. Truly, Ca. Hani Atef Bakhsh Step by step instructions to refer to Bakhsh letter, Papers

The Top 100 Transportation Jobs to Look for Right Now

The Top 100 Transportation Jobs to Look for Right Now On the off chance that you’re keen on a vocation in transportation, or in finding another profession in the field, the tides of the business are your ally. As indicated by the Bureau of Labor Statistics (BLS), employments that fall under the classification of â€Å"transportation and material moving† are anticipated to develop during that time 2024, including a huge number of occupations. Employments in transportation can fall under numerous umbrellas. Look at the most flourishing employments in the field and check whether one may be a solid match for you.Air Asset ControllerAir Traffic ControllerAircraft CaptainAircraft Quality Control InspectorAirfield Operations ManagerAirfield Operations SpecialistAirfield Operations SupervisorAirline DispatcherAirport Grounds Operations WorkerAirport ManagerAirport TransporterAirworthiness SpecialistAmbulance DriverAviation ManagerAviation Safety InspectorBoat CaptainBoat OperatorBoom Truck OperatorBulk DriverBus DriverChauffeurCla ss A DriverClass B DriverConductorCopilotDeck OfficerDock MasterDriverDriver HelperDriver ManagerDriver SupervisorDriving TeacherDump Truck OperatorEmergency Vehicle DriverEquipment MoverFlatbed Truck DriverFlight AnalystFlight AttendantFlight CoordinatorFlight EngineerFlight InstructorFlight NavigatorFlight SchedulerForklift OperatorGeneral Transportation DirectorHelicopter PilotHousehold MoverJet PilotLocomotive EngineerLog Truck DriverMapping PilotMarine OilerMedical Cylinder DriverMotor Coach OperatorOver the Road Driver (OTR Driver)Owner/OperatorPallet Jack OperatorParking Lot AttendantParking Services SpecialistParking Systems ManagerPassenger Service AgentPatient Transport DriverPick Up and Delivery DriverPilotRail Motor Coach OperatorRamp AgentRelief DriverResidential DriverRoute DriverSailorSanitation DriverService Station AttendantShip CaptainShip Chief EngineerShip NavigatorShip SuperintendentShuttle DriverSimulator InstructorSkycapStacker OperatorStreet Cleaning Equipmen t OperatorSubway and Streetcar OperatorTaxi DriverTest PilotTest Pilot ManagerTicket AgentTolling SpecialistTow Truck DriverTrain ManagerTransit DirectorTransit ManagerTransit OperatorTransit PlannerTransportation AideTransportation AnalystTransportation Facility RepresentativeTransportation InspectorTransportation Mobility ManagerTransporterTruck DriverVan DriverWheelchair Van DriverYard HostlerAccording to BLS, the middle yearly compensation for transportation occupations was $30,730 in 2016.Education prerequisites contrast for callings inside the transportation field-many request no conventional training or a secondary school confirmation, while some require a post-optional degree.This is a shifted fields with loads of chance across the nation do some looking to locate the ideal situation for your vocation objectives!

GDP Essay Example | Topics and Well Written Essays - 2000 words

Gross domestic product - Essay Example expands genuine GDP requested, and an expansion in net assessments diminishes genuine GDP requested, different things stay consistent. 4) Give short meanings of both the IS and LM bends and quickly clarify how this model can assist financial specialists with understanding the association between the merchandise and currency markets. Show how the IS and LM bends can be determined and clarify how harmony is reached. The IS bend portrays the mix of financing costs and yield that unmistakable the merchandise also, administrations showcase in the short run. The products and ventures advertise is said to clear when spending by customers, firms, the legislature (and outsiders if an open economy) on merchandise and ventures rises to the creation of products and enterprises. The fundamental condition for the IS bend in a shut economy is firmly identified with the national pay bookkeeping personality Y = C+I+G, where Y is GDP The LM bend sums up all the mixes of pay and loan costs that compare cash request and cash flexibly. The LM bend related to the IS bend will help nail down the financing cost in the economy. It is notable that setting up the versatility of the IS and LM bends gives fundamental data about the anticipated result of financial and fiscal strategies in a given model, with a blend of inelastic LM and flexible IS inferring monetary swarming out and intense money related approach, while versatile LM and inelastic IS lead to intense financial and feeble money related impacts. Estimation of these locuses 5) Distinguish between fiscal base and expansive cash. Clarify what job business banks have in the making of expansive cash. What suggestions does this have for fiscal control The money related base comprises of the liabilities of national bank of a nation which...Show how the IS and LM bends can be determined and clarify how harmony is reached. 6) Distinguish between various types of joblessness. What sort of joblessness can be diminished by flexibly side strategies and what explicitly could those approaches be Use a graph to clarify these arrangements 1) Using the Keynesian model of infusions and withdrawals in the products advertise, clarify what occurs if individuals chooses to spare more at any degree of pay. Ensure you express the procedure of modification and survey what suggestions the outcomes may have for approach.

Sade animates Newtonian virtue :: French Literature Papers

Sade enlivens Newtonian prudence Sade incorporated eighteenth century French realism into his work at a such a natural level, that it is no misrepresentation to state, as we will appear here, that his erotic entertainment sensationalizes it legitimately. I will additionally contend that there is an unequivocally good tone to his realism : that characters are required to try to do they say others should do, and to have confidence in their worth framework. The last piece of my paper will take a gander at how the restricting worth framework, Christianity, is mocked through the figure of Justine and that of the uninvolved casualties as a rule. Sade was a nonbeliever, a Lockean sensationist and a realist; he ardently read Diderot and d’Alembert’s Encyclopã ©die and the compositions of the philosophes d’Holbach, Robinet, Condillac, La Mettrie and Buffon. He littered his works with references both implicit and express to the philosophes and energetically upheld what he saw as their motivation. Their reasoning was significant to the development of his own Ã…uvre, and as he remarked himself on his composing practice, â€Å"que veux-tu qu’on fasse sans livres ? Il faut en à ªtre entourã © pour travailler, sinon on ne peut faire que des contes de fã ©es, et je n’ai pas cet esprit-lã .† [what am I expected to manage without books ? You must be encircled with them to work, else you can just do pixie stories, and I’m not that way inclined]. I want to appear here exactly how close his own work was to the realism of the philosophes. The Encyclopã ©die itself pushed a nearby explanatory connection among science and writing. The article â€Å"Lettres† clarifies that: â€Å"†¦ les lettres et les sciences proprement dites, ont entr’elles l’enchainement, les contacts, et les affinities les in addition to etroits; c’est dans l’Encyclopà ©die qu’il importe de le demontrer.† [literature and science are connected by the nearest contact and relationship; it is dependent upon the Encyclopã ©die to show this is the case]. This declaration is obviously founded on the conviction that science and writing are or ought to be about something very similar, in other words, they are about existence and nature. Life and nature, in the Encyclopã ©die, mean issue in the entirety of its different structures. Matter was characterized by the Encyclopã ©die as a â€Å"substance à ©tendue, solide, distinct, portable et passible, le head principe de

How to Cope With Anger by Taking a Time-Out

How to Cope With Anger by Taking a Time-Out PTSD Coping Print Why Adults With Anger Can Benefit From Taking a Time-Out By Matthew Tull, PhD twitter Matthew Tull, PhD is a professor of psychology at the University of Toledo, specializing in post-traumatic stress disorder. Learn about our editorial policy Matthew Tull, PhD Updated on February 09, 2020 CaiaImage / Getty Images More in PTSD Coping Causes Symptoms Diagnosis Treatment Related Conditions PTSD and the Military Anger tends to be upsetting in any case. But post-traumatic stress disorder (PTSD) can make anger much worse and even lead to violent behavior. If you have PTSD, youre probably well aware that it isnt always easy to know how to cope with anger. Here is a proven method for helping to lessen your anger  before it can get worse and some tips for making it work. The plan is to take a time-out, which means briefly removing yourself from an anger situation thats getting worse and letting yourself cool down. The steps involved in planning for a time-out and taking it are described below. How to Create Your Anger Time-Out Plan Step 1. Make a plan for how to cope with anger before you find yourself in a heated situation. The idea is to decide ahead about what youll do to cool down the situation and yourself. Think about where youll be and who else will be there. Choose a quiet, relaxing place to go on-site in case you need a time-out. Come up with some things you can do to cool down during a time-out, such as deep breathing or mindfulness exercises. Step 2. Plan what youd like to say to explain taking a time-out. Its important to be very clear and open about your feelings and your needs. Step 3. Once youre on-site, stay alert for body cues that warn a situation is getting too heated for you and your anger is increasing. Body cues may include a more rapid heart rate and a higher level of body tension. Pay attention to how your body feels. Remember, the earlier you catch your anger, the better you can manage it. Step 4. If something is making you angry that doesnt involve another person, and you can feel your anger increasing, its time for a time-out. Remove yourself from the situation as soon as you can. If you feel yourself getting angry with another person or a group, tell them you need a time out. But dont just get up and leave. Instead, explain how youre feeling and why you need to excuse yourself for a few minutes. Use I statements in your explanation. For example, dont say, You make me so angry I just have to leave the room. Instead, say, I am noticing that I am starting to get upset. So I am going to take a few minutes to calm down, and then I would like it if we could continue our conversation. Step 5. While youre explaining the actions youre going to take, make an effort to manage your anger. Try some of these coping skills for managing stress. Step 6. Once youre in your time-out space, remember that youre supposed to be cooling down. Dont get caught up in doing things that sustain or increase your anger, such as going over the situation in your mind or thinking about who said what and how it made you feel. Practicing mindfulness can help keep you from getting caught up in negative thoughts and self-talk. Step 7. After your anger has come down to a more manageable level, and before returning to the situation you left, think about what youll do and say when you get there. Take a moment to practice your plan to make sure you can stick to it. Step 8. When youre ready with your plan, return to the situation and put it into effect. If you were talking with another person or a group, express your appreciation of their understanding. Thank them for giving you the opportunity to calm down. Dealing With Anger in a Healthy Way Is Crucial Tips for Making Your Time-Out Work To give your time out plan the best chance of working to control your anger, try these tips: Plan ahead. Time-outs are not supposed to be unpredictable or sudden. Think ahead about where you can go and the things you can do during a time-out.Practice! The more you practice your time-out plan, the easier it will be to use.Time-outs are not escapes. Make sure you always return to the situation so that it can be resolved calmly and effectively.Let others know that youll be taking time-outs to help keep angry moments from getting more heated. The people you share this with will respect your commitment to your relationships with them.Keep in mind that time-outs wont always be effective. Seek out additional opportunities to learn how to cope with anger. Remember, the more tools you have for keeping your anger under control, the better you will handle it when the need arises. The 7 Best Online Anger Management Classes

The Evolution of Desktop Publishing

From its roots in the Middle Ages, layout design has evolved significantly. What was once the provenance of monasteries spread to the office, and later, personal computers. The overarching goals of publishers haven't changed, though—to find an audience and communicate an important message. However, the nuts and bolts of desktop publishing are undergoing a revolution on par with the changes precipitated by Gutenberg. When planning your business's layout design strategy, will you be ahead of the curve? Related: How visual stimulation improves client retention Illuminated manuscripts Early examples of beautiful page layouts can be found in medieval illuminated manuscripts. The work process of the manuscript creators sounds remarkably modern: they would plan the overall layout of the page, including the ornately decorated drop capital and the decorative border, then they would draw straight lines on the parchment or vellum where the text would go. The medieval publishers showed specialization in splitting the duties of the rubricators (who filled in the red text), illuminators (the illustrators—forerunners of today's graphic designers), and other scribes and artists. By the late Middle Ages, commercial scriptoria in cities were competing with the small-shop cloisters and monasteries. From the story of illuminated manuscripts we can see the importance of advance planning in thoughtful layout design, and the inevitability of commercialization and mass production. Gutenberg printing press If you've ever looked for a public-domain book, you are probably familiar with Project Gutenberg. How did the Gutenberg printing press change layout design? By using movable type to expedite the printing process, a single press could produce thousands of pages per day, as opposed to a few hand-drawn copies. During the post-Gutenberg era, some of the personalization of book layouts was lost. The use of two columns of justified text looks very modern. It lacks some of the opulent artistic qualities of the illuminated manuscript page. This era can be thought of the moment when word processing and layout design split into two distinct fields. This is still reflected in specialized programs, some aimed at text-based projects, and some more specifically aimed at visual layout design. Pre-computer layout design If you've watched a show set in the 1960s or 1970s, you know that "copy and paste" were once anything but metaphors. Before desktop publishing software, art directors, publishers, and printers physically designed their documents. Writers and journalists used typewriters, which evolved to electric typewriters, then standalone word processors. Many of the conventions of layout design were established during this period. The standardization of templates influenced the look of today's books, newspapers, and magazines, even though they're often consumed on different platforms. Mid-century layout design shows that competing mediums for design can coexist. While this era saw innovation in design tools, traditional artists and printers were still part of the media landscape. Computer desktop publishing Thirty years ago, the arrival of "What You See Is What You Get" (also known as WYSIWYG) displays radically changed layout design. Arguably, this led to an initial decline in quality: without the ability to control kerning, letter-spacing, or font selection, the printed outputs from programs like Type Processor One or PageMaker were primitive, at best. With each improvement in screen displays, processing memory, and style sheets, desktop publishing became a disruptive threat to traditional layout design. The swift evolution of WYSIWYG editors demonstrates the necessity of taking upstarts seriously—but of course, that's easier to see in hindsight! Proprietary layout software Around the year 2000, the big names in desktop publishing—InDesign, Scribus, OpenOffice, Publisher, and Pages—rolled out their products. These are still major players in the professional market. The quality of the output increased dramatically in this time period. As personal computers evolved to their now-familiar form, designers could control the digital page to look like the printed page. Cloud-based layout design software In the second decade of the new millennium, desktop publishing underwent another seismic shift. Rather than only license-based options, layout design software began a transition to the cloud. Some of the major players stopped offering their products à   la carte, switching to a subscription model. Many print magazines and newspapers ceased publication, either shutting down or becoming web-only. As internet connections became faster, browsers more reliable, and memory capacity increased, creators and consumers expected to be able to do more, to do it more quickly, and to do it better. As email became dominated by web platforms, word processing went to the browser (for example, with Google Docs), and tablets and smartphones introduced an explosion of apps, desktop publishing went to the cloud, as well. Lucidpress is one of those sleek, cloud-based desktop publishing tools. With an easy-to-understand interface, auto-saving and web publishing, and deep integration with the applications that are a part of modern business workflows (Google Docs, Dropbox, and even Facebook), it's bringing layout design out of the sphere of specialists. You no longer need an advanced degree to create high-quality print and digital publications—nor do you have to break the bank on your design software suite. The future of desktop publishing It won't be long until the notion of your layout design being tied to a single "desktop" will be as quaint as the idea of a monk cloistered away with his vellum, or a magazine made with actual glue. More designers use laptops, tablets, and cloud-based products than ever before. This space is opening up to the public. Since the software-as-a-service (SaaS) landscape is changing so quickly, it's worth re-evaluating your business's needs. What documents do you need to design to connect with your customers? How many resources are you willing to expend on desktop publishing software? Do you need the ability to share and collaborate with your team? Are you creating brochures, letterheads, flyers, reports or eBooks to be distributed? Create striking visual content in minutes with our easy-to-use desktop publishing software. Get started for free today!

The Legacy Of Darius The Great - 1306 Words

Darius I ,also known as Darius the Great, was the third king who reigned from 550-486 BCE during the Achaemenid Empire. While he lived, Darius held the empire at its peak, which stretched from the river Nile and parts of Northern Greece to the Indus River Valley. One of the most major events in Darius s life was his expedition to discipline Athens and Eretria for their support in the Ionian Revolt. He made his empire larger by vanquishing Thrace and Macedon, and occupying Scythia. He also arranged his empire, by splitting it into provinces and placing governors to rule over it. Darius organized a new financial system, along with making Aramaic the official language of the empire. He further worked on establishment projects throughout the empire. Darius also formulated a codification of laws for Egypt. He order the carving of the cliff-face Behistun Inscription, an autobiography of great modern linguistic significance. Darius also started many massive architectural projects including magnificent palaces in Persepolis, and Susa. Darius was born as the eldest of five sons to a leading figure of power in Persia named Hystaspes. Herodotus of Halicarnassus wrote that after a dream that seemed to predict Darius’ reign, King Cyrus became suspicious of the son of Hystaspes, who was â€Å"about twenty at that time and had been left behind in Persia because he was too young for war (Herodotus)†. Herodotus adds that Cyrus sent back Hystaspes to control his son. A couple days late and theShow MoreRelatedAlexander IIi Of King Of Ancient Greece1147 Words   |  5 PagesAlexander III of Macedon or commonly known as Alexander the Great was a King of Ancient Greek kingdom Macedon and a member of the Argead dynasty. He spent most of his ruling years on an extraordinary military campaign through Asia and northeast Africa and by the time he was 30 he had created one of the largest empires of the Ancient world, stretching from Greece to Egypt and into northwest India. Alexander is thought to be by most people as the greatest military command that ever lived however thisRead MoreAnalysis Of Alexander IIi The Great King Of Macedonia And Conqueror Of The Persian Empire1584 Words   |  7 Pagesâ€Å"Success without honor is an unseasoned dish; it will satisfy your hunger, but it won t taste good.† ~Joe Paterno. Alexander III the Great, King of Macedonia and conqueror of the Persian Empire is considered to be one of the best military geniuses of all times. He was inspiration for conquerors to come such as Hannibal, Napoleon, and Pompey along side Caesar. Alexander was born in 356 BC in Pella, the ancient capital of Macedonia.1 Alexander’s childhood had a major impact on his later life and hisRead MoreAlexander The Great651 Words   |  3 PagesAlexander The Great is one of the most famous icons of ancient history. He had conquered more territory than anyone else. Alexander was born in Pella the capital of Macedon in July of 356 BC. His mother was Olympias and his father was Philip II ruler of Macedon. From the age of 13-16 Alexander was tutored by the famous Aristotle. Aristotle had taught him about geography, medicine, zoology and lots of other things. Although Alexander still want to learn about military tactics which was his mainRead More Alexander The Great Essay1042 Words   |  5 Pages Alexander the Great is, arguably, the most famous secular figure in history. His magnetism in life was rivaled only by his magnetism in death, and the story of his career has evoked vastly different interpretations in his age and ours. Young romantic hero or megalomaniac villain? Alexander III of Macedon conquered all who stood before him, but usually in order to free the lower class. He did more to spread the Hellenistic culture than anyone before or after him. My credibility comes from much studyingRead MoreAlexander the Great: the Man, the Life, the Legacy Essay example1465 Words   |  6 PagesAlexander the Great: The Man, the Life, the Legacy History is full of remarkable characters. Whether they were noble or unrepentant in their actions those were what made them immortal through our recorded history. One such character is Alexander the Great. Some have accused him as a drunken killer who wanted only to have the world under his rule. Others deem him as a kind-hearted man who wanted to better the world by spreading the culture of his people. The decision of what is in the right andRead MoreThe Conquests and Legacy of Alexander the Great Essay860 Words   |  4 PagesAlexander III of Macedon, more commonly known as Alexander the Great, is one of the most legendary figures in our history and in the history of the world. His conquests and endeavors echoed far and wide, bringing about new eras and ideas to the world. Alexander earned his place in the world’s history and is worthy of the title ‘The Great’ because of his military prowess, his idealism and his legacy. During the course of his life and reign, Alexander had fought and won many battles and wars, defeatingRead MoreAlexander The Great Essay846 Words   |  4 PagesKonark Raithatha Alexander the Great Acted as ruler of Macedonia from 336 to 323 B.C. Alexander the Great unified Greece, regenerated the Corinthian League and occupied the Persian Territory. Alexander the Great was born in the Pella region of Macedonia on July 20, 356 B.C., to parents King Philip II of Macedon and Queen Olympia, daughter of King Neoptolemus. The youthful leader and his sibling were upraised in Pella s royal court. While growing up, alexander the dark-eyed and curly-headed hardlyRead MoreAlexander IIi Of Macedonia Truly Worthy Of The Title Essay953 Words   |  4 PagesAlexander III of Macedonia really worthy of the title â€Å"†Great† or was he just a megalomaniac conditioned into this belief by his followers? Well, if you consider his military legacy which is almost as large as the swath of territory he conquered spanning from modern day Greece to northern India, or the fact that his over 2,000 year old combat tactics are still being taught at military academies the world over, I donâ €™t believe the word â€Å"great† would be too far from imagination. When Alexander roseRead MoreAlexander The Second Of Macedon Essay1530 Words   |  7 PagesAlexander the Third of Macedon, commonly referred to as Alexander the Great, was king of the Ancient Macedon a Greek kingdom upon his father s death in 336 BCE. Alexander was born the son of King Philip of Macedon in the Greek city of Pella in 356 BCE. He succeeded his father and took reins of Macedon at age twenty. Alexander spent a large majority of his ruling years on an military campaign through Asia and northeast Africa. By 326 BCE at the age of thirty he lead one of the largest empires ofRead MoreThe Life Of Alexander The Great1264 Words   |  6 PagesThe Life of Alexander the Great There are many great conquers in the history of this world. Augustus Caesar, Atilla the Hun, Charlemagne, to name a few. But none of these quite measure up to Alexander III of Macedonia. Or, his more common title: Alexander the Great. He conquered much of Asia and the Persian Empire, and left a legacy that will not be forgotten. Alexander III was born in Pella, capitol of Macedonia, on July 20th 356 BC to Olympus, Princess of Epirus, and Philip II, King of Macedonia

The Theme of Deception The Adventures of Huckleberry Finn by Mark Twain - Free Essay Example

Sample details Pages: 3 Words: 1039 Downloads: 4 Date added: 2019/05/18 Category Literature Essay Level High school Tags: Huckleberry Finn Essay Mark Twain Essay Did you like this example? In The Adventures of Huckleberry Finn, the theme of deception is clearly portrayed by Mark Twain throughout the entire novel. The motives for this deception are different depending on the situation and also on the character. The book starts off with deception right away when Huck sneaks out the window of the Widows house at night and then sneaks back in later, pretending nothing happened, and the deception continues steadily throughout the novel until the last few pages when the truth seems to finally come out. Don’t waste time! Our writers will create an original "The Theme of Deception The Adventures of Huckleberry Finn by Mark Twain" essay for you Create order Huckleberry also seems to be struggling through an identity crisis throughout the novel, and the characters he meets show him in very extreme levels who he wants to be and who he doesnt want to be. His upbringing may have played a part in Huckleberry being so deceitful. For starters, his dad would steal things and call it borrowing. His mother seems to have died when he was young and his dad abused him and still abuses him, partly because he is most often found drunk. In the book there are countless examples of deception, both big and small, so much that I could never fit it all in an essay or else wed be here all day, so Ive decided to focus some of the bigger acts of deception. On page 51 of the book and continuing through the 7th chapter, Mark Twain presents the first big act of deception where Huckleberry fakes his own death. His dad would come home drunk every night and either beat him or just go crazy, and Huck would always tolerate it, but a few nights prior his dad had came close to killing him in his drunken state. Huckleberry didnt feel safe where he was, but he didnt want to go back to living a civil life with the Widow, so he decided to run away. But he wanted to run away without anyone going after him, so he decided to fake his murder, and he created a pretty good case. He killed a pig and dragged its blood everywhere, and also took many belongings from the cabin he lived in with his dad in the woods, making it look like someone had murdered him and looted the house. He also made tracks going the opposite way he was planning on going. He had recently found a canoe floating down the river at high tide, so he packed this with some belongings and sa iled off down the river. I believe in this case, deception by Huck was used for good, because he was running away from a bad situation that no child should have to endure. When Huck meets Jim on the island he first stays on, he doesnt turn Jim in as a runaway slave, but instead decides to travel with him. During their travels, Jim was often thought to be a runaway slave, so they had to come up with many different stories to keep him safe. The hiding of Jim was deceptive, because they werent letting anyone know his true identity. But this kind of deception was to protect Jim, and to keep him safe and out of the bonds of slavery, so I would argue that it was a good kind of deception. Huck thought that for sure he would go to hell because he helped Jim, and many times considered not helping him at all and turning him in, but in the end he stuck with him. Jim had a good soul, and it turns out in the end of the book that he actually was a free man all along because the Widow set him free in her will. Much later in the book on page 192, near the end of chapter 19, Huck and Jim meet two men who claim to be kings and dukes but actually werent. They just wish to be treated well and loved and respected, probably because because they had never gotten that. They in themselves were deceiving, but they also came up with plans of deception to trick people out of their money. They did phony shows that werent legitimate, but they made lots of money because people came thinking it would be great. They pretended to be people they werent, just so that they could get donations and then use that money to become rich. They even tried to pretend to be the heirs of someone wealthy who had just died, and it became a huge scandal that they just barely escaped. They used deception in a bad way to gain wealth for themselves at the expense of others. Huck didnt want to be like these men and he also didnt want to have anything to do with them. He was tired of their deceptive ways. Eventually the men got w hat they deserved, and Huck became free of them, though afterward he also pitied them. Deception can be used in so many different ways, and I believe this book does a great job at highlighting all the different ways that deception is used. It is used to protect Jim from being taken into slavery again. It is used to cheat people out of their money by pretending to be something they arent. It is used to protect Huck from his abusive father and also to set him free to a lifestyle of adventure instead of being cooped up. It is used to hide the characters identities and also to create new identities for them. And those I just mentioned were only a few out of many others. This book has shown me even more clearly how deception can be used in both good and bad ways, and also that deception is never completely good or bad. Additionally, I kept record of the deception I recognized throughout the book, and here are the page numbers I recorded: pg. 48, 51, 92, 116, 141, 156, 192, 204, 214, 222, 250, and 317. Now I obviously didnt write down all the page numbers of deception, for there would have been far too many. And I didnt include page numbers from the end of the book where Huck and Tom set free Jim in the most dangerous and extravagant way possible even though Jim is already a free man by law. I just wanted to include these numbers for future reference.

Essay on Happiness

Essay on Happiness Definition of Happiness Introduction Happiness is a complex phenomenon that functions in different ways depending on the context and the pursued aims of a particular individual. The concept of happiness is rather flexible since each separate person endows the term happiness with a unique meaning. In addition, it seems relevant to note that happiness as a notion acquires different interpretations in such spheres as philosophy, ethics, and psychology. The present paper argues that the sources of happiness (or stimuli) define the key characteristics of the phenomenon in question within the frameworks of various contexts. Philosophical Approach Happiness is understood as a state of lasting satisfaction from a particular experience. It accompanies every moment of human life and represents the highest value. The philosophical approach does not provide any specific definition of happiness but presents several theories describing various conditions associated with happiness. The scholars M. Seligman and E. Royzman note that there are three theories of happiness: hedonism, desire, objective list, and authentic happiness (Seligman Royzman). The first theory defines happiness as the preponderance of positive emotions and experience over negative ones and minimization of the latter. The second speaks about happiness as a state when somebodies’ desire is fully satisfied. The third theory is based on assumption that every person has a list of significant aim he or she pursues and the achievement of these aims is seen as the state of happiness. The last theory presents happiness as a three-piece phenomenon that includes such aspects as pleasures, engagement and meaningful life that, being combined, make a person happy. Ethical Approach This approach towards defining happiness is closely connected to the social studies and real-life manifestation of the phenomenon in question. For example, E. Kant believes that happiness is a complex phenomenon that involves such elements as continuous well-being equal to the satisfaction with life, health, power, riches, etc. However, living a life in accordance with the moral principles in incapable of satisfying all the above-mentioned needs. Ethical approach defines happiness as an ultimate goal of the moral person’s existence. However, in terms of this approach, happiness is subjected to the rule of moral principles that limit the number of the potential sources of happiness (Hughes 66). Psychological Approach This approach is based on the objective understanding of happiness as the reaction of the nervous system to certain positive experiences. This is a mental state of a person that occurs when a person reaches achieves the desired. The duration and emotional intensity of the state of happiness are determined by the cultural and intellectual development of the individual. In terms of psychological studies, happiness is strongly associated with the element of diffuse positive moods (Algoe 109). The insights presented above invite an assumption that the state of happiness could be reached at the account of various emotional stimuli. Conclusion To conclude, it seems relevant to note that happiness is interpreted in different ways in terms of different approaches. However, in terms of all approaches listed above, happiness is associated with the emotional reaction to positive stimuli. The ethical, philosophical and psychological theories define the potential sources of happiness and the ways to reach them. Ergo, they define the concept of happiness by defining particular stimuli that evoke the emotional responses associated with the state of happiness. Therefore, the ability or inability of a person to reach the state of happiness, as well as its emotional intensity, is defined by the quality and quantity of the original stimuli. Works Cited Algoe, Sara B.; Haidt, Jonathan. Witnessing excellence in action: the other-praising emotions of elevation, gratitude, and admiration. The Journal of Positive Psychology, Vol. 4 No. 2, 2009. Hughes, Julie. The Role of Happiness in Kants Ethics. Aporia, Vol. 12 No. 1, 2004. Seligman, Martin E. P. and Ed Royzman. Authentic Happiness. Accessed September 22, 2017 https://www.authentichappiness.sas.upenn.edu/newsletters/authentichappiness/happiness

Chinese Cinderella by Adeline Yen Mah - 1433 Words

As the world continues to evolve, there are various social issues that exist. Childhood neglect is problematic in society, especially in China. In Chinese Cinderella, Adeline Yen Mah exposes the severity of emotional abuse and neglect of children through her personal experiences. Literature addresses this topic through the interactions of the characters and the plot of the novel. She conveys her autobiography through antagonistic characterization and her writing style of point of view and tone. Literary critics study and comment on literary work and the issues transpired through text, which stimulate the interpretations of readers and their appreciation of literature. Not only is Adeline Yen Mahs writing piece rich, she also exposes intense concepts involving the mistreatment of children throughout the world, specifically in China. China is located in Eastern Asia where it is the third largest and most populated geographical region in the world. As the country continued to expand, th e government became more encompassed in Chinas affairs. After the Chinese emperor resigned from the throne in 1912, the Kuomintang and the Communist Party cooperated with one another to reestablish the political and militant aspects of the country. As China was under the control of Chiang, Japan managed to seize Manchuria in 1931. Throughout the years, Japan attempted to develop their territory in China. An article reports, When the Japanese captured Nanjing in December, they went on aShow MoreRelatedChinese Cinderella by Adeline Yen Mah610 Words   |  3 PagesIn the autobiography Chinese Cinderella by Adeline Yen Mah, the narrator was influenced in many ways by the people around her. One character which influences the narrator’s life to a vast amount was her step-mother Niang. Her Aunt Baba also played a very big part on how Yen Mah turned out in her later and earlier years as well as everywhere in between. Her grandfather Ye-Ye was a constant support to Adeline Yen Mah. In the book Chinese Cinderella it is apparent that Niang has had a positive andRead MoreI Have Discovered Is Adeline Yen Mah s Chinese Cinderella916 Words   |  4 Pagesconsist of, Chinese Cinderella, Life’s for the Living, Forever in our Hearts, an autobiography written by my great-great-grandfather, the phrase ‘Mind over Matter,’ and Project Semicolon. Chinese Cinderella, Life’s for the Living, and Forever in our Hearts have influenced me to be unyielding. The autobiography inspires me to work diligently and never concede. Optimism is encouraged by ‘Mind over Matter’ and The Semicolon Project. One significant autobiography that I have discovered is Adeline Yen Mah’sRead MoreChinese Cinderella Analysis1398 Words   |  6 Pagesto live with Miss Hannigan, the worst foster parent anyone could have. Annie may have struggled quite a bit, but Adeline Yen Mah had it worse. Mah was hated by her parents. They even beat her for hanging out with her friends. Even when Mah gets abused by her family, she still yearns to be loved by them. After not being involved in her family’s will, Mah ends up writing Chinese Cinderella, a story about her traumatizing childhood. She never truly tells us her reasons why she wrote this story, but weRead MoreChinese Cinderella3586 Words   |  15 PagesT a h r ’N t s eces oe W RITTEN BY SUSAN LA M ARCA Chinese Cinderella Adeline Yen Mah This book is the moving autobiography of a young Chinese girl, Adeline Yen Mah. Born the fifth child to an affluent Chinese family her life begins tragically. Adeline’s mother died shortly after her birth due to complications bought on by the delivery, and in Chinese culture this marks her as cursed or ‘bad luck’ (p.3). This situation is compounded by her father’s new marriage to a lady who has littleRead MoreChinese Cinderella Book Review910 Words   |  4 PagesThe book â€Å"Chinese Cinderella† by Adeline Yen Mah is a heart touching true story about an unwanted girl named Adeline, who longed for the compassion and love of her parent’s. While giving birth to Adeline, her mother passed away from child birth complications, leaving her father with five children to care for, including a new born. Four years later, her grandmother Nai Nai also passed away leaving her father no choice but to remarry. Soon after, her father met and fell deeply in love with a woman

Chapter 20 Free Essays

Chapter 20 Free Essays string(85) " by debt is not only contributing the property to the partnership but also the debt\." Chapter 20 Forming and Operating Partnerships Solution Manual Discussion Questions: 1. [LO 1] What is a flow-through entity, and what effect does this designation have on how business entities and their owners are taxed? Flow-through entities are entities that are not taxed on the entity level; rather, these entities are taxed on the owner’s level. These types of entities conduct a regular business; however, the income earned and deductions allowed are passed to the owners of these flow-through entities, and the owners are taxed on the amount allocated to them. We will write a custom essay sample on Chapter 20 or any similar topic only for you Order Now Thus, flow-through entities provide a way for income and deductions to be taxed only once instead of twice. 2. [LO 1] What types of business entities are taxed as flow-through entities? The two main business entities that are taxed as flow-through entities are partnerships and S corporations. Partnerships are taxed under Subchapter K and consist of general partnerships, limited partnerships, and limited liability companies (LLC). S corporations are taxed under Subchapter S. Both these types of business entities are treated as flow-through entities and are taxed accordingly. 3. LO 1] Compare and contrast the aggregate and entity concepts for taxing partnerships and their partners. The aggregate concept treats partnerships more like a conglomeration of individual owners. Each partnership is viewed as an aggregation of the partners’ separate interests in the assets and liabilities of the partnership. For example, each partner, rather than the partnership, pays tax on their indivi dual share of partnership income. The entity concept treats partnerships more like a corporation. Each partnership is an entity separate from its partners. For example, the artnership decides on which tax method to use and which tax elections to make rather than the individual partners. 4. [LO 2] What is a partnership interest, and what specific economic rights or entitlements are included with it? A partnership interest is an equity interest in a partnership. This interest is created through a transfer or sale of cash, property, or services in exchange for an equity interest in the partnership. A partnership interest gives each partner certain rights or entitlements. The two main economic rights are a capital interest and profit interest in the partnership. A capital interest is the right for a partner to receive a share of the partnership assets during liquidation. A profit interest is the right or obligation for a partner to receive a share of the future income or losses of the partnership. 5. [LO 2] What is the rationale for requiring partners to defer most gains and all losses when they contribute property to a partnership? The rationale for requiring partners to defer most gains and losses when contributing property to a partnership is twofold. First, the IRS desires that entrepreneurs have a way to start their own business without having to pay any taxes upfront. Second, the partners are considered still owning the property they have contributed to the partnership. While they don’t own the property outright, each partner has a small percentage of the property contributed in her/his partnership interest she/he exchanged for. This second reasoning helps further support the idea that partnerships follow the aggregate concept. 6. [LO 2] Under what circumstances is it possible for partners to recognize gain when contributing property to partnerships? Partners have the potential of recognizing gain on the contribution of property when the property contributed is secured by debt. In determining whether gain must be recognized, the partner must assess the cash deemed to have received from the partnership distribution compared with the tax basis of the partner’s partnership interest prior to the deemed distribution. This happens if the assumption of the partner’s liabilities is in excess of the partner’s basis of the contributed property. If the cash deemed to have received exceeds the tax basis, then a gain must be recognized. This circumstance occurs due to the negative basis created for the partner, which is not allowed under partnership tax law. . [LO 2] What is inside basis and outside basis, and why are they relevant for taxing partnerships and partners? An inside basis, in relation to partnerships, is the basis the partnership takes in the assets that the partnership holds. An outside basis, in relation to partnerships, is the tax basis each partner has in the partnership. The inside basis is necessary to compute the gain/loss recogn ized on all property sold by the partnership. The outside basis is necessary to compute the gain/loss recognized on the partnership interest when sold. For tax purposes, the inside basis is similar to the basis the partner had in the property prior to contribution. On the other hand, the outside basis corresponds not only to the contributed property, but also to the debt and income/losses of the partnership. 8. [LO 2] What is recourse and nonrecourse debt, and how is each generally allocated to partners? Recourse debt is debt for which partners are considered to have an economic risk of loss. This type of debt partners are legally liable for and must satisfy personally if the partnership cannot. An example of recourse debt is accounts payable. Nonrecourse debt is debt for which no partners are considered to have an economic risk of loss in. This is a debt for which partners are not legally liable for. An example of nonrecourse debt is a mortgage. In regards to a partnership’s debt, recourse debt is allocated to those partners that have the ultimate responsibility of paying the debt. The debt is allocated to the partners that have an economic risk of loss. On the other hand, nonrecourse debt is generally allocated to the partners according to their profit sharing ratios. Despite the partners not being legally liable for some debt, all debt is allocated to adjust the outside basis of the partners. 9. [LO 2] How does the amount of debt allocated to a partner affect the amount of gain a partner recognizes when contributing property secured by debt? A partner that contributes property secured by debt is not only contributing the property to the partnership but also the debt. You read "Chapter 20" in category "Papers" In calculating the outside basis of the partner, the partner must take her/his tax basis in the property and decrease her/his basis by the amount of the property’s debt. Next, the property’s debt is allocated to each partner according to who is ultimately responsible for it or by each partner’s profit-sharing ratio. If the partner is not allocated enough debt, the partner’s outside basis will become negative and a gain must be recognized. Thus, a partner can only avoid gain by obtaining enough of the partnership debt to keep her/his basis at least above zero. 10. [LO 2] What is a tax-basis capital account, and what type of tax-related information does it provide? A tax-basis capital account is an equity account that is created for each partner of the partnership. This account is measured using the tax accounting rules. The account reflects tax basis of any capital contributions (i. e. , property and cash), capital distributions, and future earnings and losses allocated to that partner. Additionally, a tax-basis capital account can provide more tax-related information for each partner. For instance, each partner’s share of inside basis of the partnership’s assets can be calculated by adding the partner’s share of debt to her/his capital account. Furthermore, if a partner acquires her/his interests by contributing property tax-free, then the partner’s outside basis will be equal to that partner’s share of partnership inside basis. 11. [LO 2] Distinguish between a capital interest and a profits interest, and explain how partners and partnerships treat when exchanging them for services provided. A partnership interest can be broken down into two distinct rights: (1) capital interest and (2) profits interest. To become a partner in a partnership, you will receive at least one of these rights. A capital interest is the right to receive a share of the partnership assets at liquidation. A profits interest is the right to share in the future earnings and losses of the partnership. While these rights are given to most partners that contribute cash or property, special rules exist when these rights are given to partners in exchange for services. When a partner receives a capital interest in exchange for services rendered to the partnership, the partner must treat the liquidation value of the capital interest as ordinary income. Further, the tax basis for the partner will be equivalent to the amount of ordinary income recognized. The holding period for this tax basis will begin on the date the capital interest is received. From the partnership’s perspective, the partnership can deduct or capitalize the value of the capital interest depending upon the type of services rendered. This is determined on a fact and circumstance basis. Additionally, the amount deducted by the partnership is allocated to the non-service partners as consideration for effectively transferring a portion of their capital interest to the service partner. When a partner receives a profit interest in exchange for services rendered to the partnership, the partner has no immediate tax impact because they have no liquidation value at the time they are received. Thus, the non-service partners will not receive any deductions for the additional partner to the partnership. As the partnership makes future profits and losses, the service partner will be allocated her/his portion of these losses according to the profit sharing ratios. The debt allocated to non-service partners must also be redistributed with the additional service partner receiving her/his portion of debt. Therefore, the tax basis of a service partner with only a profit interest will either be zero or the portion of debt the partner is allocated. 12. [LO 2] How do partners who purchase a partnership interest determine the tax basis and holding period of their partnership interests? When a partner purchases a partnership interest, the initial tax basis for the partner is a determined by taking the cost basis of the interest the partner purchased and adding to this basis any debt allocated to the partner’s interest. The holding period for this purchased interest will begin on the date that the partner purchased the partnership interest. 3. [LO 3] Why do you think partnerships, rather than the individual partners, are responsible for making most of the tax elections related to the operation of the partnership? The responsibility for the partnership, not the partners, to make the majority of tax elections regarding the operation of the partnership is twofold. First, partnerships can consist of many different partners ranging from two to hundreds. The hassle to obtain every partner’s approval on what elections to make would be very time consuming. The costs would more than likely outweigh the benefits in performing this function. Second, in many partnerships only a few partners are actively involved in the management of the partnership. The limited partners have ownership to obtain a tax advantage on their own personal returns. Thus, the entity concept would appear more reasonable when dealing with the actual operations of the partnership. 14. [LO 3] If a partner with a taxable year-end of December 31 is in a partnership with a March 31 taxable year-end, how many months of deferral will the partner receive? Why? A partner with a calendar year end will receive nine months of deferral in her/his partnership interest that has a March 31 year end. A partner must report the income or loss of the partnership not at the partner’s year end but at the partnership’s year end. Thus, the first year of the partnership will be reported by the partner on her/his return which includes the partnership’s year end, which allows the partner to defer the first nine months of income or loss from the partnership into the succeeding tax year. 15. [LO 3] In what situation will there be a common year-end for the principal partners when there is no majority interest taxable year? The principal partner test states that the required tax year is the taxable year all the principal partners have in common. A principal partner is a partner that owns at least 5 percent interest in the partnership profits and capital. For the principal partner test to pass and not the majority interest test, the partnership must consists of numerous partners that (1) own less than 5 percent profit and capital interest and (2) have a variety of fiscal year ends. For example, if four partners with a calendar year end owned 10 percent and 20 additional partners with differing fiscal year ends owned less than 5 percent, then the majority test would not pass, but the principal partners test would. 6. [LO 3] Explain the least aggregate deferral test for determining a partnership’s year end and discuss when it applies. The least aggregate deferral test is the last resort test that a partnership must follow when figuring out the partnership year end. The first test is the majority interest test. The second test is the principal partners test. If these two tests don’t apply, along with the exception to elect an alternative year end, then the least aggregate deferral test goes into effect. The least aggregate deferral test selects the tax year which provides the partner group as a whole the smallest amount of aggregate tax deferral. This is calculated by taking each partner’s months of deferral under the potential tax year and weighting it with the partner’s profit interest percentage. Then, each partner’s weighted totals are summed up to come up with an aggregate deferral number. The potential tax year that produces the smallest aggregate deferral must be the one chosen by the partnership. 17. [LO 3] When are partnerships eligible to use the cash method of accounting? Under the tax accounting rules, a partnership with a corporate partner must use the accrual method of accounting unless the following exception applies. A partnership with a corporate partner is eligible to use the cash method of accounting when the partnership has average gross receipts over the past three taxable years less than or equal to $5 million. 18. [LO 4] What is a partnership’s ordinary business income (loss) and how is it calculated? Through the course of business, partnerships create income or losses. Some of these items are considered to affect a specific partner or groups of partners differently. Thus, these separately-stated items must be reported on a partner-by-partner basis. Then, after adjusting the partnership’s business income (loss) for these separately-stated items, the partnership reports the remaining amount of business income (loss) to ordinary business income (loss). The total amount will be allocated to each partner according to the special allocation rules agreed upon or else based upon the profit sharing ratios of the partnership. 19. [LO 4] What are some common separately stated items, and why must they be separately stated to the partners? Separately-stated items must be taken out of ordinary income (loss) because these items either (1) relate only to a specific partner in the partnership or (2) the item is taxed differently for each partner depending upon the entity of the partner and the partner’s current tax situation. The following is a partial list of items that are separately stated on a partnership return. 1. Short-term capital gains (losses) 2. Long-term capital gains (losses) 3. Section 1231 gains (losses) 4. Charitable contributions 5. Dividends 6. Interest income 7. Guaranteed payments 8. Net earnings (losses) from self-employment . Tax-exempt income 10. Net rental real estate income (loss) 11. Investment interest expense 12. Section 179 deductions 20. [LO 4] Is the character of partnership income/gains and expenses/losses determined at the partnership or partner level? Why? In keeping with the entity concept, the character of all income/gains and expenses/losses is determined at the partnership level . Despite the chance that specific items would change character depending upon the partner who holds them, the IRS has decided to unify the character of all items by looking at the character from the partnership’s perspective. Thus, partnerships are required to file a 1065 return along with all partners’ K-1s to help audit the amounts and character that show up on the individual partner’s return. 21. [LO 4] What are guaranteed payments and how do partnerships and partners treat them for income and self-employment tax purposes? Guaranteed payments are similar to cash salary payments for services provided. The idea behind a guaranteed payment is for a partner to receive a fixed amount of income no matter the profit (loss) for the partnership’s taxable year. Thus, on the partnership level, hey are treated like a salary payment to an unrelated party. The partnership deducts the guaranteed payment in computing the partnership’s ordinary business income (loss). On the partner level, the partner that receives a guaranteed payment must account for the guaranteed payment as a separately-stated item that is taxed as ordinary income. Further, the partner must include the amount of the guar anteed payment in computing self-employment income for tax purposes. This amount is included no matter if the partner is a general partner, limited partner, or LLC member. 22. LO 4] How do general and limited partners treat their share of ordinary business income for self-employment tax purposes? In determining how different partners treat their share of ordinary business income, the IRS assesses the involvement the partner has in the partnership. General partners are considered to be actively involved in the management of the partnership. Thus, the general partner’s share of ordinary business income is treated as trade or business income and is subject to self-employment tax. Conversely, limited partners are generally not actively involved with managing the partnership. The limited partner’s share of ordinary business income is treated as investment income and not subject to self-employment tax. Both types of partners must treat guaranteed payments as income relating to self-employment; however, the ordinary business income depends on the type of partner. 23. [LO 4] What challenges do LLCs face when deciding whether to treat their members’ shares of ordinary business income as self-employment income? Due to the lack of authoritative ruling that exists for LLCs, members must decide on their own whether to include ordinary business income as self-employment income or not. A proposed regulation gave us clarity on this matter; however, the regulation was withdrawn. Members of an LLC should still review this proposed regulation to understand the stance the IRS is trying to take and whether they will take an aggressive or conservative stance for their specific situation. The proposed regulation helped clarify that if an LLC member is involved in the operations of the LLC, the member should treat the ordinary business income as self-employment income. The regulation listed the following three criteria that would demonstrate active involvement in the LLC: (1) personally liable for the debt of the LLC as an LLC member, (2) authority to contract on behalf of the LLC, or (3) participate in more than 500 hours in the LLC’s trade or business during the taxable year. If any one of these requirements is met, then the LLC member would be more associated as a general partner and should more than likely account for the ordinary business income as self-employment income. 24. [LO 4] How much flexibility do partnerships have in allocating partnership items to partners? Partnerships have a great deal of flexibility in determining how to allocate partnership items to partners, both separately-stated and non-separately stated items. The determining factors must be (1) the partners agree upon the allocations and (2) the allocations have substantial economic effect. The second factor is put into place to make sure the allocations are being accomplished for a business objective and not just to reduce or avoid taxes. While both of these items need to be met for a special allocation of a partnership item, certain items have mandatory allocations to specific partners. For example, contributed property built-in gain (loss) must be allocated to the partner who contributed the property when the property is sold. Any additional gain (loss) will be allocated according to the partnership agreement. Overall, if the partnership has no mandatory allocations or does not specify and meet the requirements for special allocations, the partnership will allocate according to the capital or profit interest. 25. [LO4] What are the basic tax-filing requirements imposed on partnerships? While a partnership does not pay taxes, the IRS still requires all partnerships to file an information return to the IRS – Form 1065 (U. S. Return of Partnership Income). This form must be filed by the 15th day of the 4th month of the partnership’s year end. For calendar year end partnerships, the form must be filed by April 15th. An extension is available to file by the due date of the original return and provides the partnership an additional five months to file Form 1065. The extension must be filed on Form 7004. The tax return that must be filed by all partnerships consists of a detailed calculation of the partnerships ordinary business income (loss) on page 1 of Form 1065. On page 3 of Form 1065, Schedule K must be filled out which lists the ordinary business income (loss) along with any separately-stated items. This schedule is an aggregate of each partner’s share of items both separately-stated and non-separately stated. In addition, each partner’s proportion of the above items is reported on a Schedule K-1. A Schedule K-1 for every partner must be filed with Form 1065, and each individual partner will receive her/his own Schedule K-1 from the partnership. 26. [LO 5] In what situations do partners need to know the tax basis in their partnership interests? Partners should always keep track of the tax basis in their partnership interest; however, certain situations require partners to actually know their tax basis. These situations include when a partner sells her/his partnership interest or when a partner receives a distribution from the partnership. The main reasoning is to help the partner figure out the amount of gain which s/he most report on her/his current tax return. 27. [LO 5] Why does a partner’s tax basis in her partnership need to be adjusted annually? A partner’s tax basis needs to be adjusted annually for the following three reasons. First, a partner does not want to double count any income/gain from the partnership when she/he sells her/his partnership interest or receive a distribution from the partnership. Second, the IRS does not want partners to double count any expenses/losses from the partnership in a similar situation from above. Last, partners want to make sure they adjust for tax-exempt income and non-deductible expenses, so these items will not ultimately be taxed or deducted at the time of selling a partnership interest or receiving a distribution from the partnership. 28. [LO 5] What items will increase a partner’s basis in her partnership interest? The following items will increase a partner’s basis and must be adjusted for on an annual basis in the order given. 1. Actual and deemed cash contributions to the partnership 2. Partner’s share of ordinary business income 3. Partner’s share of separately-stated income/gain items and 4. Partner’s share of tax-exempt income 29. [LO 5] What items will decrease a partner’s basis in her partnership interest? The following items will decrease a partner’s basis and must be adjusted for on an annual basis in the order given. These items will be adjusted after all the increases to a partner’s basis have been taken into effect. 1. Actual and deemed cash distributions from the partnership 2. Partner’s share of non-deductible expenses (fines, penalties, etc. ) 3. Partner’s share of ordinary business losses and 4. Partner’s share of separately-stated expenses/loss items 30. [LO 6] What hurdles (or limitations) must partners overcome before they can ultimately deduct partnership losses on their tax returns? While a partnership can create an ordinary business loss, the individual partners potentially will not be able to deduct the entire amount in the year of the loss. The partner must overcome three loss limitation rules before the deduction is available. If the loss does not pass any of the limitations, then the loss is suspended indefinitely under that specific hurdle. The three loss limitations are (1) the tax basis limitation, (2) the at-risk loss limitation, and (3) the passive activity loss limitation. First, a partner is not able to take any losses that exceed the tax basis of the partner, the partner’s outside basis. This limitation prevents partners from taking losses beyond their investment or basis in their partnership interests. Second, a partner cannot take any losses that exceed the at-risk amount for the partner. The at-risk amount is generally the same as the partner’s tax basis, except that it excludes the partner’s share of nonrecourse debt. This limit still includes recourse debt and qualified nonrecourse debt. Finally, in the case of a passive participant in a partnership, losses cannot be taken if the loss exceeds the amount of passive income reported by the partner. Passive losses such as losses from rental activities or losses allocated to a limited partner can only be offset with passive gains. 31. [LO 6] What happens to partnership losses allocated to partners in excess of the tax basis in their partnership interests? Losses that are allocated to partners that exceed the partner’s tax basis cannot be used during the current taxable year. The excess loss will be suspended and carried forward indefinitely until the partner has sufficient basis to utilize the losses. A partner would be able to increase her/his tax basis by (1) making a capital contribution, (2) guaranteeing more partnership debt, or (3) helping the partnership become more profitable. Once the partner’s tax basis is positive, the losses previously suspended can be used. 32. [LO 6] In what sense is the at-risk loss limitation rule more restrictive than the tax basis loss limitation rule? While the at-risk loss limitation and tax basis loss limitation are basically the same, one difference exists between the two different hurdles a partner must overcome when faced with losses. The at-risk loss limitation only accounts for those items that the partner is at risk for. The major item that is not included under the at-risk calculation but is included in the tax basis is nonrecourse debt. As a note, qualified nonrecourse debt is still considered to be part of the partner’s at-risk calculation. 33. [LO 6] How do partners measure the amount they have at risk in the partnership? A partner will measure her/his partnership at-risk amount by looking at what items affect the partner’s economic risk of loss. In most cases, items included in the at-risk amount would include cash contributed, tax basis of property contributed, recourse debt, qualified nonrecourse debt, and any other adjustments to the partner’s tax basis excluding nonrecourse debt. Nonrecourse debt is considered a part of the tax basis but not a part of the at-risk basis since the partner does not have an economic risk of loss for this type of debt. 34. [LO 6] In what order are the loss limitation rules applied to limit partner’s losses from partnerships? The order of the hurdles a partner must pass for the loss limitation rules are (1) tax basis loss limitation, (2) at-risk loss limitation, and (3) passive activity loss limitation. As the losses exceed the limitation in each hurdle, the suspended losses will be carried forward indefinitely within each group until enough basis or income is generated to cover these losses. Once the loss has passed all three limitations, the partner can use the loss as a deduction on her/his own personal return. 35. [LO 6] How do partners determine whether they are passive participants in partnerships when applying the passive activity loss limitation rules? According to the Code, a partner is considered to be a passive participant if the activity conducted is a trade or business and the partner does not materially participate in the activity. The IRS has made it clear that those participants in rental activities and limited partners within a partnership are automatically considered to be passive participants. Further, regulations help clarify whether a partner would be considered a material participant. If the partner meets any of the conditions below, then the partner would be a material participant and the activity would not be considered a passive activity to the partner. . The individual participates in the activity more than 500 hours during the year. | 2. The individual’s activity constitutes substantially all of the participation in such activity by individuals. | 3. The individual participates more than 100 hours during the year and the individual’s participation is not less than any other individual’s parti cipation in the activity. | 4. The activity qualifies as a â€Å"significant participation activity† (individual participates for more than 100 hours during the year) and the aggregate of all other â€Å"significant participation activities† is greater than 500 hours for the year. | 5. The individual materially participated in the activity for any 5 of the preceding 10 taxable years. | 6. The activity involves personal services in health, law, accounting, architecture, and so on, and the individual materially participated for any three preceding years. | 7. Taking into account all the facts and circumstances, the individual participates on a regular, continuous, and substantial basis during the year. | 36. [LO 6] Under what circumstances can partners with passive losses from partnerships deduct their passive losses? A partner may deduct the passive losses she/he has generated from a partnership under three circumstances. First, a passive loss is not deductible until the taxpayer generates current year passive income in the activity producing the loss. Second, a passive loss is not deductible until the taxpayer generates current year passive income from another passive activity the taxpayer is involved with. Last, a passive loss will not be deductible unless the taxpayer sells the activity that has produced the passive loss. In this case, the taxpayer will report a gain or loss on the sale and can use the passive loss to offset this or any other source of income ( i. . , active income, portfolio income, or other passive income). Problems 37. [LO 2] Joseph contributed $22,000 in cash and equipment with a tax basis of $5,000 and a fair market value of $11,000 to Berry Hill Partnership in exchange for a partnership interest. a. What is Joseph’s tax basis in his partnership interest? b. What is Berry Hill’s basis in the equipment? a. $27,000. Joseph’s tax basis is considered to be his outside basis in the partnership. The tax basis includes the $22,000 in cash and his original basis in the equipment, $5,000. Joseph’s holding period for his outside basis would depend upon the holding period of the assets contributed. If property contributed is a capital or Section 1231 asset, the holding period for that portion of the partnership interest includes the holding period of the contributed property. Otherwise, the holding period of the partnership interest begins on the date it is received. b. $5,000. Berry Hill Partnership’s basis in the equipment is a carryover basis from the partner who contributed the equipment. The basis in the equipment plus the basis in the cash will give us Berry Hill Partnership’s inside basis. The holding period for the equipment carries over to the Berry Hill Partnership from Joseph. 38. [ LO 2] Lance contributed investment property worth $500,000, purchased three years ago for $200,000 cash, to Cloud Peak LLC in exchange for an 85 percent profits and capital interest in the LLC. Cloud Peak owes $300,000 to its suppliers but has no other debts. a. What is Lance’s tax basis in his LLC interest? b. What is Lance’s holding period in his interest? c. What is Cloud Peak’s basis in the contributed property? d. What is Cloud Peak’s holding period in the contributed property? a. $455,000. Lance’s basis in his LLC interest is made up of the $200,000 basis of the investment property he transferred to the LLC and his $255,000 share of the LLC debt (85% x $300,000). Because LLC general debt obligations are treated as nonrecourse debt, Lance’s profit sharing ratio is used to allocate a portion of the LLC debt to him. b. Three years. Because Lance contributed a capital asset, the holding period of the contributed assets â€Å"tacks onto† his partnership interest. c. $200,000. The LLC takes a carryover basis in the contributed property. d. Three years. The LLC inherits Lance’s holding period in the contributed property. 9. [ LO 2] Laurel contributed equipment worth $200,000, purchased 10 months ago for $250,000 cash and used in her sole proprietorship, to Sand Creek LLC in exchange for a 15 percent profits and capital interest in the LLC. Laurel agreed to guarantee all $15,000 of Sand Creek’s accounts payable, but she did not guarantee any portion of the $100,000 nonrecourse mortgage securing Sand Creek’s office building. Other than the accounts payable and mortgage, Sand Creek does not owe any debts to other creditors. a. What is Laurel’s initial tax basis in her LLC interest? b. What is Laurel’s holding period in her interest? c. What is Sand Creek’s initial basis in the contributed property? d. What is Sand Creek’s holding period in the contributed property? a. $280,000. Laurel’s basis in her LLC interest is made up of the $250,000 basis in the equipment (no depreciation was taken on the equipment prior to the contribution because it was acquired and contributed within the same calendar year) Laurel contributed, her $15,000 share of accounts payable that she guaranteed, and her $15,000 share of the nonrecourse mortgage securing Sand Creek’s office building (15% x $100,000). Laurel’s profits sharing ratio is used to allocate a portion of the mortgage to her because it is nonrecourse debt. b. Laurel’s holding period begins the day the LLC interest is acquired because the asset she contributed is not a capital or Section 1231 asset. The equipment is not a Section 1231 asset because it was used in a trade or business for one year or less. c. $250,000. The LLC takes a carryover basis in the contributed property. d. Ten months. Laurel’s holding period is included in the LLC’s holding period regardless of the nature of the property Laurel contributed. 0. [LO 2] {Planning}Harry and Sally formed the Evergreen partnership by contributing the following assets in exchange for a 50 percent capital and profits interest in the partnership: Harry:Basis Fair Market Value Cash$ 30,000$ 30,000 Land100,000120,000 Totals$ 130,000$ 150,000 Sally: Equipment used in a business200,000150,000 Totals$ 200,000$ 150,000 a. How much gain or loss will Harr y recognize on the contribution? b. How much gain or loss will Sally recognize on the contribution? c. How could the transaction be structured a different way to get a better result for Sally? . What is Harry’s tax basis in his partnership interest? e. What is Sally’s tax basis in her partnership interest? f. What is Evergreen’s tax basis in its assets? g. Following the format in Exhibit 20-2, prepare a tax basis balance sheet for the Evergreen partnership showing the tax capital accounts for the partners. a. $0. Generally, partners recognize gain on property contributed to a partnership only when the cash they are deemed to receive from debt relief exceeds their basis in the partnership prior to the deemed distribution. Harry did not have any debt relief. . $0. Partners may never recognize loss when property is contributed to a partnership even when they are relieved of debt. c. Sally should consider selling the property to the partnership rather than contribut ing it. By selling the property, she could recognize the $50,000 built-in loss on the equipment. d. $130,000. Harry’s basis in his partnership interest is simply the combined tax basis in the cash and land he contributed to the partnership. e. $200,000. Sally’s basis in her partnership interest equals $200,000 basis in the equipment she contributed. f. $330,000. The partnership’s basis in its assets equals the sum of the partners’ bases in the cash ($30,000), in the land ($100,000), and in the equipment ($200,000). g. The partnership’s tax basis balance sheet would appear as follows: Evergreen PartnershipTax Basis Balance Sheet| | Tax Basis| Assets:| | Cash| $30,000| Equipment| 200,000| Land| 100,000| Totals| $330,000| Capital:| | Capital-Harry| 130,000| Capital-Sally| 200,000| Totals| $330,000| 41. [LO 2] Cosmo contributed land with a fair market value of $400,000 and a tax basis of $90,000 to the Y Mountain partnership in exchange for a 25 percent profits and capital interest in the partnership. The land is secured by $120,000 of nonrecourse debt. Other than this nonrecourse debt, Y Mountain partnership does not have any debt. a. How much gain will Cosmo recognize from the contribution? b. What is Cosmo’s tax basis in his partnership interest? a. $0. As reflected in the table below, Cosmo does not recognize any gain because the $120,000 of cash he is deemed to receive from debt relief does not exceed his basis in Y Mountain prior to this deemed distribution. Description| Cosmo| Explanation| (1) Basis in contributed Land| $90,000| | 2) Nonrecourse mortgage in excess of basis in contributed land| $30,000| Nonrecourse debt basis is allocated only to Cosmo | (3) Remaining nonrecourse mortgage | $22,500| 25% x [120,000 – (2)]| (4) Relief from mortgage debt| ($120,000)| | Cosmo’s initial tax basis in Y Mountain| $22,500| (1) + (2) + (3) + (4) | b. $22,500 as indicated in the table above. 42. [LO2] When High Horizon LLC was formed, Maude contributed the follow ing assets in exchange for a 25 percent capital and profits interest in the LLC: Maude:Basis Fair Market Value Cash$ 20,000$ 20,000 Land*100,000200,000 Totals$ 120,000$ 220,000 *Nonrecourse debt secured by the land equals $160,000 James, Harold and Jenny each contributed $220,000 in cash for a 25% profits and capital interest. a. How much gain or loss will Maude and the other members recognize? b. What is Maude’s tax basis in her LLC interest? c. What tax basis do James, Harold, and Jenny have in their LLC interests? d. What is High Horizon’s tax basis in its assets? e. Following the format in Exhibit 20-2, prepare a tax basis balance sheet for the High Horizon LLC showing the tax capital accounts for the members. . $0. None of the members recognize gain because their debt relief was not in excess of their bases in their LLC interest prior to any debt relief. See table below: Description| Maude| Other Members| Explanation| (1) Basis in contributed Land| $100,000| | | (2) Cash contributed| $20,000| $220,000| | (3) Nonrecourse mortgage in excess of basis in contributed land| $60,000| | Nonrecourse deb t basis is allocated only to Maude | (4) Remaining nonrecourse mortgage | $25,000| $25,000| 25% x [160,000 – (3)]| (5) Relief from mortgage debt| ($160,000)| | | Each member’s initial tax basis in the LLC| $45,000| $245,000| (1) + (2) + (3) + (4) + (5)| b. $45,000. See table in part a. above. c. $245,000 each. See table in part a. above. d. $780,000. High Horizon takes a $120,000 carryover basis in the assets Maude contributes and a $660,000 in the total cash the other three members contributed. e. High Horizon’s tax basis balance sheet would appear as follows: High Horizons, LLCTax Basis Balance Sheet| | Tax Basis| Assets:| | Cash| $680,000| Land| 100,000| Totals| 780,000| Liabilities and Capital:| | Mortgage debt| 160,000| Capital-Maude| (40,000)| Capital-James| 220,000| Capital-Harold| 220,000| Capital-Jenny| 220,000| Totals| 780,000| Note that the members’ tax capital accounts are equal to their bases in the LLC interests less their individual shares of LLC debt. 43. [LO2] Kevan, Jerry, and Dave formed Albee LLC. Jerry and Dave each contributed $245,000 in cash. Kevan contributed the following assets: Kevan:Basis Fair Market Value Cash$ 15,000$ 15,000 Land*120,000230,000 Totals$ 135,000$ 245,000 *Nonrecourse debt secured by the land equals $210,000 Each member received a one-third capital and profits interest in the LLC. . How much gain or loss will Jerry, Dave and Kevan recognize on the contributions? b. What is Kevan’s tax basis in his LLC interest? c. What tax basis do Jerry and Dave have in their LLC interests? d. What is Albee LLC’s tax basis in its assets? e. Following the format in Exhibit 20-2, prepare a tax basis balance sheet for the Albee LLC showing the tax capital accounts for the members. W hat is Kevan’s share of the LLC’s inside basis? f. If the lender holding the nonrecourse debt secured by Kevan’s land required Kevan to guarantee 33. 3 percent of the debt and Jerry to guarantee the remaining 66. 67 percent of the debt when Albee LLC was formed, how much gain or loss will Kevan recognize? g. If the lender holding the nonrecourse debt secured by Kevan’s land required Kevan to guarantee 33. 33 percent of the debt and Jerry to guarantee the remaining 66. 67 percent of the debt when Albee LLC was formed, what are the members’ tax bases in their LLC interests? a. $0. None of the members recognize gain because their debt relief was not in excess of their bases in their LLC interest prior to any debt relief. See table below: Description| Kevan| Other Members| Explanation| (1) Basis in contributed Land| $120,000| | | (2) Cash contributed| $15,000| $245,000| | (3) Nonrecourse mortgage in excess of basis in contributed land| $90,000| | Nonrecourse debt basis is allocated only to Kevan | (4) Remaining nonrecourse mortgage | $40,000| $40,000| 33. 3% x [$210,000 – (3)]| (5) Relief from mortgage debt| ($210,000)| | | Each member’s initial tax basis in the LLC| $55,000| $285,000| (1) + (2) + (3) + (4)+ (5)| b. $55,000. See table in part a. above. c. $285,000 each. See table in part a. above. d. $625,000. Albee, LLC takes a $135,000 carryover basis in the assets Kevan contributes and a $490,000 in the total cash the other two members contributed. e. Albee, LLC’s tax basis balance sheet would appear as follows: Albee , LLCTax Basis Balance Sheet| | Tax Basis| Assets:| | Cash| $505,000| Land| 120,000| Totals| 625,000| Liabilities and Capital:| | Mortgage debt| 210,000| Capital-Kevan| (75,000)| Capital-Jerry| 245,000| Capital-Dave| 245,000| Totals| 625,000| Note that the members’ tax capital accounts are equal to their bases in the LLC interests less their individual shares of LLC debt. . $5,000. See table below: Description| Kevan| Jerry| Dave| Explanation| (1) Basis in contributed Land| $120,000| | | | (2) Cash contributed| $15,000| $245,000| $245,000| | (3) Mortgage Guarantee | $70,000| $140,000| $0| 33. 33% x $210,000 for Kevan and 66. 67% x $210,000 for Jerry| (4) Relief from mortgage debt| ($210,000)| | | | (5) Gain Recognized| $5,000| $0| $0| [(1)+ (2)+ (3) + (4)]| E ach member’s initial tax basis in the LLC| $0| $385,000| $245,000| (1) + (2) + (3)+ (4) + (5)| g. Kevan’s basis is $0, Jerry’s basis is $385,000, and Dave’s basis is $245,000. See the table in part f. above. 44. [LO2] {Research} Jim has decided to contribute some equipment he previously used in his sole proprietorship in exchange for a 10 percent profits and capital interest in Fast Choppers LLC. Jim originally paid $200,000 cash for the equipment. Since then, the tax basis in the equipment has been reduced to $100,000 because of tax depreciation, and the fair market value of the equipment is now $150,000. a. Must Jim recognize any of the potential  § 1245 recapture when he contributes the machinery to Fast Choppers? {Hint: See  § 1245(b)(3). } b. What cost recovery method will Fast Choppers use to depreciate the machinery? {Hint: See  § 168(i)(7). } c. If Fast Choppers were to immediately sell the equipment Jim contributed for $150,000, how much gain would Jim recognize and what is its character? {Hint: See  § 1245 and 704(c). } a. According to Section 1245(b)(3), recapture potential on property contributed to a partnership is only recognized to the extent any gain is recognized from the contribution of property. Because Jim was not relieved of any debt in the transaction, he will not recognize gain from the contribution under Section 721. Therefore, Jim does not recognize any of the Section 1245 recapture potential on the equipment at the time of contribution. b. According to Section 168(i)(7), a transferee partnership will step into the shoes of the transferor partner for purposes of depreciating contributed equipment. In this situation, Fast Choppers will continue to depreciate the equipment using the same method instituted by Jim over the remaining useful life of the equipment. In other words, the annual depreciation calculation will proceed as if the property were still held by Jim. c. Under Section 704(c), all $50,000 of gain recognized from the sale of the equipment would be allocated to Jim because this gain was built-in at the time the equipment was contributed. Moreover, the Section 1245 recapture potential remains with the equipment after the contribution; as a result, all $50,000 of gain recognized (the lesser of the $50,000 gain recognized or the $100,000 depreciation taken) must be characterized as Section 1245 recapture income. 45. [LO2] {Research} Ansel purchased raw land three years ago for $200,000 to hold as an investment. After watching the value of the land drop to $150,000, he decided to contribute it to Mountainside Developers LLC in exchange for a 5 percent capital and profits interest. Mountainside plans to develop the property and will treat it as inventory, like all of the other real estate it holds. a. If Mountainside sells the property for $150,000 after holding it for one year, how much gain or loss does it recognize, and what is the character of its gain or loss? {Hint: See  §724. } b. If Mountainside sells the property for $125,000 after holding it for two years, how much gain or loss does it recognize, and what is the character of the gain or loss? . If Mountainside sells the property for $150,000 after holding it six years, how much gain or loss is recognized, and what is the character of the gain or loss? a. According to Section 724(c), recognized losses on assets that were capital assets in the hands of contributing partners are treated as capital losses up to the amount of loss buil t into the assets at the time they were contributed if they are sold within a five year period beginning on the date of contribution. Thus, Mountainside Developers will recognize a $50,000 loss characterized as a capital rather than an ordinary loss. b. In this instance, Mountainside Developers will recognize a $75,000 loss from the sale of the land. The built-in loss at the time the land was contributed or $50,000 will be characterized as a capital loss, and the remaining $25,000 loss will be characterized as an ordinary loss per Section 724(c). c. Because Mountainside Developers held the land as inventory for more than five years, it will recognize a $50,000 ordinary loss per Section 724(c). 46. [LO2] {Research} Claude purchased raw land three years ago for $1,500,000 to develop into lots and sell to individuals planning to build their dream homes. Claude intended to treat this property as inventory, like his other development properties. Before completing the development of the property, however, he decided to contribute it to South Peak Investors LLC when it was worth $2,500,000, in exchange for a 10 percent capital and profits interest. South Peak’s strategy is to hold land for investment purposes only and then sell it later at a gain. a. If South Peak sells the property for $3,000,000 four years after Claude’s contribution, how much gain or loss is recognized and what is its character? {Hint: See  § 724. } b. If South Peak sells the property for $3,000,000 five and one-half years after Claude’s contribution, how much gain or loss is recognized and what is its character? a. Under Section 724(b), any gain or loss on contributed property that was treated as inventory by the contributing partner and sold by the partnership during the five year period beginning on the date of contribution is treated as ordinary gain or loss. Thus, the entire $1,500,000 gain from the sale of the land will be treated as ordinary gain. b. Section 724(b) only applies if contributed property is sold during the five year period beginning on the date of contribution. Because South Peak sold the land after the expiration of this time period and held the land as investment property, it should recognize $1,500,000 of capital gain. 47. [LO2] {Research} Reggie contributed $10,000 in cash and a capital asset he had held for three years with a fair market value of $20,000 and tax basis of $10,000 for a 5 percent capital and profits interest in Green Valley LLC. a. If Reggie sells his LLC interest thirteen months later for $30,000 when the tax basis in his partnership interest is still $20,000, how much gain does he report and what is its character? b. If Reggie sells his LLC interest two months later for $30,000 when the tax basis in his partnership interest is still $20,000, how much gain does he report and what is its character? {Hint: See Reg.  §1. 1223-3} a. Reggie sold his LLC interest, a capital asset, for $30,000 when he had a basis in the LLC interest of $20,000. Thus, he will recognize a $10,000 capital gain. The capital gain is treated as a long-term capital gain because he has held his LLC interest for more than twelve months. In this situation, the holding period of his LLC interest at the date he contributed property is irrelevant. b. Under Reg.  §1. 223-3(b)(1), the holding period of Reggie’s LLC interest is based on the relative fair market value of the property he contributed. Since two-thirds of the value of the property he contributed was a capital asset held for three years, two- thirds of his LLC interest is treated as being held for three years and the remaining one-third of his LLC interest has a h olding period that begins on the date of contribution. Under Reg.  §1. 1223-3(c)(1), two-thirds or $6,667 of the resulting $10,000 capital gain from the sale will be treated as long-term capital gain and the remaining one-third or $3,333 will be treated as short-term capital gain. 8. [LO2] Connie recently provided legal services to the Winterhaven LLC and received a 5 percent interest in the LLC as compensation. Winterhaven currently has $50,000 of accounts payable and no other debt. The current fair market value of Winterhaven’s capital is $200,000. a. If Connie receives a 5 percent capital interest only, how much income must she report, and what is her tax basis in the LLC interest? b. If Connie receives a 5 percent profits interest only, how much income must she report, and what is her tax basis in the LLC interest? c. If Connie receives a 5 percent capital and profits interest, how much income must she report, and what is her tax basis in the LLC interest? a. Connie reports $10,000 of ordinary income or 5 percent of the LLC’s capital of $200,000. Her basis in the LLC interest is also $10,000. b. Connie will not report any income but will have a basis in the LLC interest equal to her share of the LLC’s debt. Because the LLC’s debt is a nonrecourse debt, it must be allocated to her using Connie’s profits interest. Thus, her basis in the LLC equals $2,500 or 5 percent of the LLC’s $50,000 accounts payable. c. Connie reports $10,000 of ordinary income or 5 percent of the LLC’s capital of $200,000. Her basis in the LLC is $12,500 consisting of the $10,000 of income she recognizes for the receipt of her capital interest and her $2,500 share of the LLC’s nonrecourse accounts payable. 49. [LO2] Mary and Scott formed a partnership that maintains its records on a calendar-year basis. The balance sheet of the MS Partnership at year-end is as follows: Basis Fair Market Value Cash $ 60 $ 60 Land 60180 Inventory 72 60 $192 $300 Mary$ 96 $150 Scott 96 150 192 $300 At the end of the current year, Kari will receive a one-third capital interest only in exchange for services rendered. Kari’s interest will not be subject to a substantial risk of forfeiture and the costs for the type of services she provided are typically not capitalized by the partnership. For the current year, the income and expenses from operations are equal. Consequently, the only tax consequences for the year are those relating to the admission of Kari to the partnership. a. Compute and characterize any gain or loss Kari may have to recognize as a result of her admission to the partnership. . Compute Kari’s basis in her partnership interest. c. Prepare a balance sheet of the partnership immediately after Kari’s admission showing the partners’ tax capital accounts and capital accounts stated at fair market value. d. Calculate how much gain or loss Kari would have to recognize if, instead of a capital interest, she only received a profits interest. a. Kari will recognize one-third of the fair market value of the partnership’s capital or $100 as ordinary income. b. Kari’s basis in her partnership interest will be equal to the amount of income she reports or $100. . Immediately after Kari’s admission into the partnership the partnership’s balance sheet will appear as follows: MS PartnershipBalance Sheet| | Tax Basis| 704(b)/FMV| Assets:| | | Cash| $60| 60| Land| 60| 180| Inventory| 72| 60| Totals| $192| 300| Capital:| | | Capital-Mary| 46| 100| Capital-Scott| 46| 100| Capital-Kari| 100| 100| Totals| $192| $300| Essentially, the tax capital and 704(b) capital accounts for both Scott and Mary are reduced by their $50 share of the $100 compensation expense the partnership will deduct for the capital interest Kari receives. d. If Kari only receives a profits interest, she will not recognize any income until she receives a profits allocation from the partnership. 50. [LO2] Dave LaCroix recently received a 10 percent capital and profits interest in Cirque Capital LLC in exchange for consulting services he provided. If Cirque Capital had paid an outsider to provide the advice, it would have deducted the payment as compensation expense. Cirque Capital’s balance sheet on the day Dave received his capital interest appears below: Assets: Basis Fair Market Value Cash$ 150,000 $ 150,000 Investments200,000700,000 Land150,000250,000 Totals$ 500,000$1,100,000 Liabilities and capital: Nonrecourse Debt100,000100,000 Lance*200,000500,000 Robert*200,000500,000 Totals $ 500,000 $ 1,100,000 *Assume that Lance’s basis and Robert’s basis in their LLC interests equal their tax basis capital accounts plus their respective shares of nonrecourse debt. a. Compute and characterize any gain or loss Dave may have to recognize as a result of his admission to Cirque Capital. b. Compute each member’s tax basis in his LLC interest immediately after Dave’s receipt of his interest. c. Prepare a balance sheet for Cirque Capital immediately after Dave’s admission showing the members’ tax capital accounts and their capital accounts stated at fair market value. d. Compute and characterize any gain or loss Dave may have to recognize as a result of his admission to Cirque Capital if he receives only a profits interest. e. Compute each member’s tax basis in his LLC interest immediately after Dave’s receipt of his interest if Dave only receives a profits interest. a. The tax consequences of giving Dave both a 10 percent capital and profits interest are summarized in the following table: Description| Dave| Lance| Robert| Explanation| (1) Beginning Basis in LLC| $0| $250,000| $250,000| $200,000 tax basis capital account + [. 5 x $100,000 nonrecourse debt]| (2) Ordinary Income | $100,000| | | Liquidation Value of Capital Interest (. 1 x $1,000,000 fair market value of LLC capital)| (3) Ordinary Deduction| | ($50,000)| ($50,000)| Capital Shift from Non-Service Partners. (2) x . 5| (4) Increase in Debt Allocation| $10,000| | | [$100,000 nonrecourse debt x 10% profit sharing ratio]| (5) Decrease in Debt Allocation| | (5,000)| (5,000)| (4) x . | (6) Ending Basis in LLC| $110,000| $195,000| $195,000| (1) + (2) + (3) + (4) + (5)| As indicated in line (2) of the table above, Dave recognizes $100,000 of ordinary income. b. As indicated in line (6) of the table above, the member’s tax bases in the LLC interests immediately after Dave is admitted are as follows: $110,000 for Dave and $195,000 for Lance and Robert. c. Immediately after Dave’s admission into the LLC, the LLC’s balance sheet will appear as follows: Cirque, LLCBalance Sheet| | Tax Basis| 704(b/)FMV| Assets:| | | Cash| $150,000| $150,000| Land| 200,000| 700,000| Inventory| 150,000| 250,000| Totals| $500,000| $1,100,000| Capital:| | | Nonrecourse Debt| $100,000| 100,000| Capital-Lance| 150,000| 450,000| Capital-Robert| 150,000| 450,000| Capital-Dave| 100,000| 100,000| Totals| $500,000| $1,100,000| d. The tax consequences of giving Dave only a 10 percent profits interest are summarized in the following table: Description| Dave| Lance| Robert| Explanation| (1) Beginning Basis in LLC| $0| $250,000| $250,000| $200,000 tax basis capital account + [. 5 x $100,000 nonrecourse debt]| (2) Ordinary Income| $0| | | Dave does not recognize any income because he only receives a profits interest. | 3) Increase in Debt Allocation| $10,000| | | [$100,000 nonrecourse debt x 10% profit sharing ratio]| (4) Decrease in Debt Allocation| | (5,000)| (5,000)| (3) x . 5| (5) Ending Basis in LLC| $10,000| $245,000| $245,000| (1) + (2) + (3) + (4) | Dave does not recognize any income because he only received a profits interest. e. As reflected in line (5) of the table above, Dave’s basis is $10,000, Lance’s basis is $245,000, and Robert’s basis is $245,000. 51. [LO 2] Last December 31, Ramon sold the 10 percent interest in the Del Sol Partnership that he had held for two years to Garrett for $400,000. Prior to selling his interest, Ramon’s basis in Del Sol was $200,000 which included a $100,000 share of nonrecourse debt allocated to him. a. What is Garrett’s tax basis in his partnership interest? b. If Garrett sells his partnership interests three months after receiving it and recognizes a gain, what is the character of his gain? Garrett’s basis in his partnership interest is equal to the $400,000 amount he paid for it plus his $100,000 share of partnership debt or $500,000. a. Because Garrett purchased his partnership interest, his holding period for the interest begins on the date the interest was purchased. As a result, he only has a three month holding period before the partnership interest is sold. This means his capital gain from the sale of his partnership interest will be short-term capital gain. 52. [LO 3] Broken Rock LLC was recently formed with the following members: Name| Tax Year End| Capital/Profits %| George Allen| December 31| 33. 33%| Elanax Corp. | June 30| 33. 33%| Ray Kirk| December 31| 33. 34%| What is the required taxable year-end for Broken Rock LLC? George Allen and Ray Kirk together own more than 50 percent of the profits and capital of Broken Rock. Because both George and Ray have a December 31 year end, December 31 is majority interest taxable year and is also the required year end for Broken Rock. 53. [LO 3] Granite Slab LLC was recently formed with the following members: Name| Tax Year End| Capital/Profits %| Nelson Black| December 31| 22. 0%| Brittany Jones| December 31| 24. 0%| Lone Pine LLC| June 30| 4. 5%| Red Spot Inc. | October 31 | 4. 5%| Pale Rock Inc. | September 30 | 4. 5%| Thunder Ridge LLC| July 31 | 4. 5%| Alpensee LLC| March 31 | 4. 5%| Lakewood Inc. | June 30| 4. 5%| Streamside LLC| October 31 | 4. 5%| Burnt Fork Inc. October 31 | 4. 5%| Snowy Ridge LP| June 30| 4. 5%| Whitewater LP| October 31| 4. 5%| Straw Hat LLC| January 31 | 4. 5%| Wildfire Inc. | September 30 | 4. 5%| What is the required taxable year-end for Granite Slab LLC? Because none of the partners with the same year end together own more than 50 percent of the capital and profits of Granite Slab, there is no majority interest taxable year. Howeve r, Nelson Black and Brittany Jones are principal partners because they individually own 5 percent or more of the profits and capital of Granite Slab. Moreover, they both have a December 31 year end. Therefore, the required year end of the partnership is the year end of the principal partners or December 31. 54. [LO 3] Tall Tree LLC was recently formed with the following members: Name| Tax Year End| Capital/Profits %| Eddie Robinson| December 31| 40%| Pitcher Lenders LLC| June 30| 25%| Perry Homes Inc. | October 31 | 35%| What is the required taxable year-end for Tall Tree LLC? Tall Tree does not have a majority interest taxable year because no partner or group of partners with the same year end owns more than 50 percent of the profits and capital interests in Tall Tree. Also, because all three principal partners in Tall Tree have different year ends, the principal partner test is not met. As a result, Tall Tree must decide which of three potential year ends, December 31, June 30, or October 31, will provide its members the least aggregate deferral. The table below illustrates the required computations: Possible Year Ends| 12/31 Year End| 6/30 Year End| 10/31 Year End| Members| % How to cite Chapter 20, Papers