10.10 Several years ago, Ashley, Beatrice and Charlie each contributed $120,000 to a newly formed partnership. Ashley contributed cash, Beatrice contributed investment land with a tax basis of $30,000 and Charlie contributed investment stock with a tax basis of $40,000. The partnership uses the traditional method for applying section 704(c). The partnership has not yet found an appropriate investment for its cash, and its balance sheet today, expanded to show asset values, looks like this:
Assets Tax Book FMV
Cash $120,000 $120,000 $120,000
Land 30,000 120,000 180,000
Stock 40,000 120,000 90,000
Total Assets $190,000 $360,000 $390,000
Liabilities Tax Book
[None] $ 0 $ 0
Capital
Ashley 120,000 120,000
Beatrice 30,000 120,000
Charlie 40,000 120,000
Total Liabilities and Capital $190,000 $360,000
Daniel buys Charlie's partnership interest for $130,000 cash and in connection with this acquisition the partnership makes an election under section 754. What amount of Daniel's special basis adjustment is allocated to each of the partnership's assets?
a) Land, $20,000; stock, $50,000
b) Land, $20,000; stock, $50,000; section 197 intangible, $20,000
c) Land, $30,000; stock, $60,000
d) Land, $23,222; stock, $46,667