Arielle

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Jenna began the year with a tax basis of $45,000 in her partnership interest.

Her
share of partnership debt consists of $6,000 of recourse debt and $10,000 of
nonrecourse debt at the beginning of the year and $6,000 of recourse debt and
$13,000 of nonrecourse debt at the end of the year. During the year, she was
allocated $65,000 of partnership ordinary business loss. Jenna does not
materially participate in this partnership and she has $4,000 of passive income
from other sources.

a. How much of Jennas loss is limited by her tax basis?

Loss limited by tax basis 17000


As Jennas share of nonrecourse debt climbed by $3,000 during the year, thus
basis prior to any loss allocation is $48,000 ($45,000 beginning tax basis + $3,000
rise in nonrecourse debt allocation). Hence, $48,000 of Jenna $65,000 loss
allocation is not limited by her tax basis and the balance $17,000 is limited and
carried over to the following year
b. How much of Jennas loss is limited by her at-risk amount?

Loss limited by at risk $13000


Of the total amount of $48,000 loss not already limited by Jennas tax basis,
$13,000 is limited as Jennas at-risk amount is only $35,000 ($48,000 regular tax
basis minus $13,000 nonrecourse debt that was not allowed in calculating the at-
risk amount at the end of the year). Therefore, $35,000 of loss remains after the
tax basis and at-risk limitations, and Jenna has a amount of $13,000 at-risk
carryover.

c. How much of Jennas loss is limited by the passive activity loss rules?

Loss limited by passive activity $31000


As Jenna doesnt materially participate in the partnership, thus may only deduct
the $35,000 loss remaining after the tax basis and at-risk limitations to the extent
Jenna's has passive income from other sources. Therefore, Jenna is allowed to
deduct $4,000 of the $35,000 loss currently and may have a $31,000 passive
activity loss carryover

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