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ACCT 442 – Spring 2020 – Research Memo
Topic: Allocation of MACRS under Reg. 1.704 -1 and -2
Document Type: Research Paper
Subject: Accounting
Deadline:*: As Per Required
Number of Words: 500+
Citation/Referencing Style: APA
Your clients, Tidewell Investments, Inc. (Rosa Parkington, President), and Tory Chadwell, each contributed $200,000 of cash to form the Virtual Management Partnership, a limited partnership. Tidewell is the general partner, and Tory is the limited partner. The partnership used the $400,000 cash to make a down payment on a building. The rest of the building’s $4,000,000 purchase price was financed with an interest-only nonrecourse loan of $3,600,000, which was obtained from an independent third-party bank.
All partnership items are allocated equally between the partners except for the MACRS deductions and building maintenance, which are allocated 70% to Tory and 30% to Tidewell. The partnership wants to satisfy the “economic effect” requirements of Reg. §§ 1.704–1 and 1.704–2 and will reallocate MACRS, if necessary, to satisfy the requirements of the Regulations.
Under the partnership agreement, liquidation distributions will be paid in proportion to the partners’ positive capital account balances. Capital accounts are maintained as required in the Regulations.
Tidewell Investments has an unlimited obligation to restore its capital account, while Tory is subject to a qualified income offset provision.
Assume that all partnership items, except for MACRS, will net to zero throughout the first three years of the partnership operations. Also assume that each year’s MACRS deduction will be $200,000 (to simplify the calculations).
Research Memo Project:
Prepare a tax research memo, following the guidelines as found in the course syllabus, evaluating the allocation of MACRS in each of the three years under Reg. §§ 1.704–1 and –2.
Due Date:
Monday, April 20th
Additional Guidance:
Consultation with your peers is allowed. Indeed, I think it should be encouraged. This would normally be considered an advanced research project for undergraduate students, perhaps appropriate for graduate students. But, as I advised at the start of ACCT 441, by the time we finish the Tax Assistance Program, you will be doing graduate tax work.
We’re there
Feel free to consult with anyone (& everyone) in class. But, do not seek guidance outside of the classroom, with the sole exception being conduct your research in Checkpoint.
Also, remember to make your final project reflect your work. Write your memo without the assistance of anyone else. And, do not share your written memo (or any early draft of it) with anyone else. See the appropriate business department policies regarding cheating.
Good luck. And, enjoy the challenge!
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