Wolford General Partnership Case Summary

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Facts Wolford General Partnership (WGP) operates plumbing supply business which is also an exclusive supplier for certain stable construction firms. Because of its excellent reputations and services, WGP is able to an extremely profitable entity for the business. WGP uses an accrual method of accounting and has been using June 30 fiscal year for the tax report purpose after its election of §444 since its formation. WGP currently has three business partners: Eli Wolford, Ethan Wolford, and Nora Latham which owes 60%, 20%, 20% shares of the partnership, respectively. Each partner has a tax basis equal to the capital account balance plus each share of partnership liabilities. According to the balance sheet of the partnership as of June 30, …show more content…

According to the Regs. §1.708-1(b)(4), if the partnership occurs such a Technical Termination, “The partnership contributes all of its assets and liabilities to a new partnership in exchange for an interest in the new partnership; and, immediately thereafter, the terminated partnership distributes interests in the new partnership to the purchasing partner and the other remaining partners in proportion to their respective interests in the terminated partnership in liquidation of the terminated partnership, either for the continuation of the business by the new partnership or for its dissolution and winding up.” Thus, it becomes a deemed new partnership. There are groups of tax consequences followed by this Technical Termination. Depending on different areas, some of the consequences do change; otherwise remain. For instance, depreciation will be restarted under §168(i)(7). This means the deemed new partnership may use a new depreciation method. Additionally, because it is deemed new partnership, the new partnership can many new elections. For example, accounting method and tax year end. The partners or partnership should also have to pay attention to how to file their tax returns since it would be much

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