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TXX5771 Betty is a one-third partner in the BCD Partnership. The partnership has the following assets:
Fair Market Value
Cash $30,000 $30,000
Accounts Receivable 0 60,000
Total Assets $30,000 $90,000
Capital - Betty $10,000 $30,000
Capital - Carry 10,000 30,000
Capital- Darry 10,000 30,000
Distribution of one-half of the receivables to Betty:
Betty's interests before and after the distribution:
Pre-Distribution Post-Distribution Change
Ordinary Income Assets:
Accounts Receivable $20,000 $30,000 $10,000
Other Assets:
Cash $10,000 0 (10,000)
a)What are the tax consequences to Betty?
b)Will Code Section 751(b) apply? If so, why? If not, why not?