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 Jenna's loss is limited by her tax basis?B) How much of Jenna's loss is further limited by her at-risk amount?C) How much of Jenna's loss is further limited by the passive activity loss rules?

Answer:

a) Jenna's tax basis = $45,000 + ($13,000 - $10,000) = $48,000

loss allocation = $65,000

loss limited by her tax basis = $65,000 - $48,000 = $17,000

b)  Jenna's at risk loss = $48,000 - $13,000 = $35,000

c) Jenna's loss limited by passive activity = $35,000 - $4,000 = $31,000

The amount of loss limited by Jenna’s tax basis is $20,000; the amount of Jenna’s loss that is further limited by her at-risk amount is $10,000; and the amount of Jenna’s loss that is further limited by the passive activity loss rules is $31,000.

The basis for each partner's tax base is the sum of the partner's contribution amount and the share of the debt and any income earned. Distribution reduces the partner tax base.

Calculations of The Amount of Loss Limited Tax Basis, At-Risk Amount, and Passive Activity Loss Rules:

a) Amount of loss limited by Jenna’s tax basis is Loss allocated to Jena – Jena’s Tax Basis.

[tex]\rm\,Amount\; of \;loss \;limited\; by \;Jennas\; tax\; basis\; = \$65,000 - \$45,000[/tex]

Amount of loss limited by Jenna’s tax basis is $20,000

B) The amount of Jenna’s loss that is further limited by her at-risk amount can be calculated as follows: is At-risk limitation - Amount of loss limited by Jenna’s tax basis  (1)

Where:

[tex]\rm\, At-risk\, limitation = Loss \,allocated \,to \,Jena - At\,-risk \,amount\, limitation\, \\\\= \,Loss\, allocated\, to\, Jena\, - (\,Tax \,basis\, - Nonrecourse\, Debt)[/tex]

[tex]= \$65,000 - (\$45,000 - \$10,000) \\= \$30,000[/tex]

Substituting the relevant values into equation (1), we have:

Amount of Jenna’s loss that is further limited by her at-risk amount

[tex]= \$30,000 - \$20,000\\ = \$10,000[/tex]

C) The amount of Jenna’s loss that is further limited by the passive activity loss rules can be calculated as follows:

Amount of Jenna’s loss that is further limited by the passive activity loss rules:

[tex]= \rm\,At-risk\; amount \;limitation - Passive \;income \\= Tax \;basis - Nonrecourse\; Debt) - Passive \;income \\= (\$45,000 - \$10,000) - \$4,000 \\= \$31,000[/tex]

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