These are basically ordinary income producing assets, such as accounts receivable not already recognized as income, LIFO reserves, appreciated inventory, and depreciation recapture. The amount subject to recharacterization is the lesser of (1) the prior depreciation deductions allowed or allowable; or (2) the taxpayer's gain on the property (Regs. One common depreciation recapture example involves qualified improvement property (QIP). If so, did the partnership correctly compute the section 743(b) adjustment. 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. For example, when negotiating terms of installment payments for a partnership interest, the seller may consider that installment gain treatment is generally not available for gains from ordinary income items such as the sale of inventory, certain accounts receivable, recapture items, and securities traded on an established exchange. This property exchange takes its name from Section 1031 of the Internal Revenue Code (IRC). Issue 2: Did the partner who sold an interest in the partnership properly report the gain or loss? The $1,000 gain would be allocated equally ($500) to A and B, but the Sec. Special tax provisions, however, apply with respect to the calculation of gain on property acquired before June 1, 1971. Example 1 (from above)- Sale of Partnership interest with no debt: Assume Amys basis was $40,000. QIP includes certain improvements to the interior portion of nonresidential real property (Sec. Loss from the sale or exchange of that property is not deductible. The following steps provide more detail about the process: If the asset is a fixed asset, verify that it has been depreciated through the end of the last reporting period. For example, consider a taxpayer that acquired $1,500 of QIP for which it claimed bonus depreciation in the year placed in service. The sale date is 9/30, with year to date Net Income of $100,000 (9 months), $50,000 to be added to each partners capital account, less any distributions made (we can assume $0). The title of this transaction unit (as referred to by the IRS) is:Sale of a partnership interest. However, if the partnership holds certain assets, the aggregate theory trumps the entity theory and requires the partner to characterize part of the gain or loss as subject to varying rates ( e.g., ordinary . What is the difference between book and tax basis? Generally, a partner selling his partnership interest recognizes capital gain or loss on the sale. In order to obtain the capital gains or losses on assets, you must have the basis amount, which is the amount paid to acquire the asset. 1.1245-1(e)(2)(iii) walk through situations of nonratable allocations and their impact on allocations of recapture. >0(tEMC]J;QQ!x)n? brbz/xd2N;(]5a,"fp`Ma|S|39'W;73;^r(aupu]gxH O8G)HGKH/beE%,Lw 6gtp]Sb2( (-8S##q'x?J^$+q]!L_Os^Tbfz by`scPE9=U,)%D8/V kbew=d %in T[31n9b(g The sale of capital assets results in capital gain or loss. 1.1245-1(e)(2). The residual methodmust be used for any transfer of a group of assets that constitutes a trade or business and for which the buyer's basis is determined only by the amount paid for the assets. 1250 gain rules may apply. Taxpayers and their advisers need to understand the depreciation recapture rules to fully evaluate the tax consequences of various transactions. The calculation would be as follows-. But this compensation does not influence the information we publish, or the reviews that you see on this site. A seller, informed in advance of tax consequences of the proposed transaction, is also better positioned to negotiate payment terms, negotiate terms of consent to potential partnership-level elections, and ultimately to maximize her partnership interest offering price. Sec. 'https://':'http://')+'wufoo.com/scripts/embed/form.js';s.onload=s.onreadystatechange=function(){var rs=this.readyState;if(rs)if(rs!='complete')if(rs!='loaded')return;try{r1itk61y0m3hvj2=new WufooForm();r1itk61y0m3hvj2.initialize(options);r1itk61y0m3hvj2.display();}catch(e){}} Although the partnership does provide an analysis of the changes to your capital account in item L of Schedule K-1, that information is based on the partnership's books and records and cannot be used to figure your basis. VDOMDHTMLtml>. What are index funds and how do they work? For a full discussion of the effect of Code Sec. Further, if the partnership has liabilities, the amount realized will include the partners share of the partnership liabilities. All reviews are prepared by our staff. 751(a) applies to the sale or exchange of a partnership interest and treats amounts realized from certain partnership property, unrealized receivables, and inventory items as from other than a capital asset (i.e., ordinary gain). For example, A contributes property with an adjusted basis to him of $400 (and a value of $1,000) to a partnership. endstream endobj 2165 0 obj <>/Metadata 201 0 R/Names 2179 0 R/OCProperties<>/OCGs[2180 0 R]>>/Outlines 276 0 R/PageLayout/SinglePage/Pages 2151 0 R/StructTreeRoot 377 0 R/Type/Catalog/ViewerPreferences<>>> endobj 2166 0 obj <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageC/ImageI]/Properties<>/Shading<>/XObject<>>>/Rotate 0/StructParents 760/Tabs/S/Type/Page>> endobj 2167 0 obj <>stream partnership interest. What to do when you lose your 401(k) match, which could be as high as 37 percent on your 2022 tax return, How to deduct stock losses from your taxes, Need to report cryptocurrency on your taxes? The net asset value (or balance sheet) method relies generally on the value of the assets of the company net of its liabilities. Also assume, the gain on the sale allocated to Joe's estate is $20,000, and the estate took $500 of depreciation on the step-up. The additional depreciation would be reduced going forward by the amount of straight-line depreciation the taxpayer would have been allowed for such year. endstream endobj startxref In the case of property which at the time of disposition has a holding period under section 1223 of more than 1 year, the depreciation adjustments in excess of straight line for periods after December 31, 1963, computed under paragraph (b)(1) of this section. What if just before the sale, both partners took distributions of their capital accounts, i.e., each partner took out $50,000 (assume this is from their starting 1/1 balance). In its simplest form, Sec. Our editorial team does not receive direct compensation from our advertisers. continues to operate as a partnership with two members. The IRS recently released final regulations supporting Sec. The use of the assets would constitute an active trade or business under section 355 of the Internal Revenue Code. Depending on your answers to the various Schedule D questions, youre directed to the separate Qualified Dividends and Capital Gain Tax worksheet or the Schedule D Tax worksheet, which are found in the Form 1040 instructions booklet. B AIPR Q J@! Depreciable real property does not generally qualify for Sec. The situations discussed above are by no means all the potential circumstances that require additional analysis to determine the proper amount and allocation of Secs. Depreciable real property is often, but not always, depreciated utilizing the straight-line method. Many partnerships will need to compute and report "tax basis capital" and "unrecognized section 704 (c) gain or . Ms. A's 2016 and 2017 tax years Of the $5,000,000 Ms. A will receive in each of 2016 and 2017, $4,500,000 will be reportable as gain attributable to the sale, and $500,000 will be recovery of basis. subject matter experts, Depreciation or amortization is a critical issue for these entities because this deduction can shield economic income from taxes. 1245, Sec. Under IRC Section 741, when a partner sells his interest, he is entitled to capital gain treatment, except as provided in IRC Section 751. 1245 gain. To calculate the gross profit percentage for a contingent payment sale, the regs assume that 100% of the possible contingent payments will be made in the shortest period of time permissible and use that maximum purchase price to calculate the gross profit percentage. One straightforward question is: what would the selling partners tax-basis be ($100k or $50k)? However, what would happen if the property had been contributed by one of the partners, there was a change in the partnership ownership, or the partnership had made special allocations of depreciation? A business usually has many assets. hWmo8+%H+$@]w%>6$(IW')QFWSU@g8sY G"WHx$-! His work has been cited by CNBC, the Washington Post, The New York Times and more. 1245 and 1250 become more nuanced. Said differently, how are capital accounts handled when an LLC interest is sold (in real dollar terms, separate from the tax-basis question). However, under the definitions in both sections, some real property may fall under the Sec. All transactions require the same information, entered in either Part 1 (short term) or Part 2 (long term), in the appropriate alphabetically designated column. To start you must report any transactions first on Form 8949 and then transfer the info to Schedule D. On Form 8949 youll note when you bought the asset and when you sold it, as well as what it cost and what you sold it for. BR Tech Services, Inc. NMLS ID #1743443 | NMLS Consumer Access. Another example, let's say your overall gain is $15,000 and your share of hot assets is $25,000. However, Section 751 provides an important exception; the seller realizes ordinary income for your share of the hot assets. Issue 4: Did the selling partner consider whether the partnership has any section 1250 assets and treat any of the gain or loss on the sale of the partnership interest as being subject to tax at the unrecaptured section 1250 gain tax rate? To the extent that C is entitled to depreciation from the property, whether related to its allocation of tax depreciation on the property or its special basis adjustment under Sec. As a bonus, your capital loss means youre through with Schedule D. You simply transfer your loss amount to your 1040 and continue your filing work there. As a pass through entity, income earned from the LLC flows through to the partners 50/50 and is tax at the individuals ordinary income rate. Auto-suggest helps you quickly narrow down your search results by suggesting possible matches as you type. Previous Question Next Question Back To All Questions What are partnership liquidations relating to death or retirement? In today's partnership environment of targeted allocations and profits/carried interests, these rules are significant. So, how must a seller determine the character of gain or loss from the sale of a partnership interest? An official website of the United States Government. While we adhere to strict Opinions expressed are solely those of the reviewer and have not been reviewed or approved by any advertiser. The partner will be able to offset the $450,000 sales proceeds with 45% of such partner's adjusted basis of $700,000, and then will recognize a gain in the amount of $135.000 on the partial sale of 45% of the building to the partnership. The market method or income method is most often used when the closely held company carries on an active trade or business. Once you clear up the issues in item 2, you need to prepare your basis. 1245 as opposed to having $1,200 of potential ordinary income recapture under Sec. A couple of lines in Part 3 also deal with special rates for collectibles and depreciated real estate. The general purpose of Secs. This section essentially consolidates the work you did earlier, but its not as easy as simply transferring numbers from the front of the schedule to the back. The principal and sole office location of the Law Office of Michael A. Sanchez, PLLC is Bellaire, Texas. Bankrate does not offer advisory or brokerage services, nor does it provide individualized recommendations or personalized investment advice. Sec. This amount represents the difference between the cost of his partnership interest and his share of partnership basis at the time of his purchase. Been with Intuit for going on 6 years now. This helpsheet explains these briefly. Youll have to file a Schedule D form if you realized any capital gains or losses from your investments in taxable accounts. 1245, Sec. 1.1245-1(e)(2)(ii)(C)(1)). this post may contain references to products from our partners. Marrying ESG initiatives to business tax planning, Early access to wages may require new employment tax analyses, Determining gross receipts under Sec. When you come up with a gain, the tax paperwork continues. 1245 rules. For more information, see Internal Revenue Code section 332 and its regulations. but wait there could be . Those who have realized capital gains or losses from a partnership, estate, trust or S corporation will need to report those to the IRS on this form. Our articles, interactive tools, and hypothetical examples contain information to help you conduct research but are not intended to serve as investment advice, and we cannot guarantee that this information is applicable or accurate to your personal circumstances. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006. So Ending balance at time of sale is $100,000 for each partner. Sec. Principal writer, investing and wealth management, Get in contact with James Royal via Email. Their outside basis would decrease to $15,000 (their initial contribution - their gain from the partnership). 1250. 165(g)(3), Recent changes to the Sec. Sec. A seller also may wish to defray current tax costs by considering that the buyer will want a step-up in basis in underlying assets represented by her acquired partnership interest; the buyer may be willing to pay a premium to obtain the selling partners consent to a partnership-level election, a necessity to the buyers inside basis step-up. The net asset value is most often used when a closely held company holds primarily real . Should you accept an early retirement offer? The effect on C's purchase of the partnership interest in the above example may be best summarized in the preamble to regulations proposed in 2014 but not finalized, REG-151416-06: The intent of the regulations under 1.1245-1(e)(3) is, in part, to ensure that a transferee partner does not recognize ordinary income with respect to section 1245 property to the extent a section 743 adjustment has displaced that ordinary income. Heres how to use Form 8949 to do it, California Consumer Financial Privacy Notice. Prior to the contribution, B had acquired the property for $500 and claimed $500 of depreciation. in Mand MBA, Enrolled Agent. The content created by our editorial staff is objective, factual, and not influenced by our advertisers. 84-53, which compares the debt deemed transferred to C ($48, one half of $96) to the total debt allocated to A ($96) and multiplies that fraction by A's total basis in his partnership interest ($90). $500,000 to be paid to the selling partner, before any adjustments. Secs. 1. You have everything you need to determine your tax basis based on what I see in your facts (assuming you get clarification on the discrepancies noted above and in your facts). A Red Ventures company. Please advise. 1245 and 1250 have been explained, this item will discuss some aspects of real property depreciation recapture in more detail and then look at situations involving the application of depreciation recapture rules in the partnership context. After first providing background on Secs. 1(h)(1)(E) subjects unrecaptured Sec. To find out more about how to make the allocation among assets in proportion, refertoPublication 544,Sales and Other Dispositions of Assets. Remember, the IRS received a copy of any tax statement your broker sent you, so the agency is expecting you to detail the sale, and gain or loss, with your tax filing. No member firm has any authority to obligate or bind KPMG International or any other member firm vis--vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. 2178 0 obj <>/Filter/FlateDecode/ID[<63008A1AC6D12C458EF462444204D569>]/Index[2164 32]/Info 2163 0 R/Length 86/Prev 536788/Root 2165 0 R/Size 2196/Type/XRef/W[1 3 1]>>stream Unlike Sec. Our award-winning editors and reporters create honest and accurate content to help you make the right financial decisions. The taxpayer would have been allowed $100 of straight-line depreciation per year if bonus depreciation had not been claimed. things may be complicated for both the buyer and seller. However, there are a number of common circumstances where gains on the disposition of real property could be subject to recapture of prior depreciation, in whole or part, as ordinary income. We do not include the universe of companies or financial offers that may be available to you. question 5. 1250 gain of $20, the lesser of the additional depreciation ($20) or gain on the property ($150). 743(b)] . 741. 1250 regulations provide that "the amount of gain recognized under section 1250(a) by the partnership and by a partner shall be determined in a manner consistent with the principles provided in paragraph (e) of 1.1245-1" (Regs. Partnership AB elects to use the remedial allocation method, which results in $200 of book depreciation ($1,000 5) per year allocable equally to A andB. Investing involves risk including the potential loss of principal. It would seem not, if an EBITDA multiple approach was taken, for example. At Bankrate we strive to help you make smarter financial decisions. Generally, the selling partner treats the gain or loss on the sale of a partnership interest as the sale of a capital asset. Fortunately, the regulations under both Secs. gain (loss) when you sell or otherwise dispose of your interest in the entity. There the partnership had two equal partners since inception, and, assuming all allocations were pro rata, A and B would each be allocated half of the Sec. Calculating Gain on a Disguised Sale Interactive WORKSHEET W120: Determining Qualification for and Calculating the Exclusion for Discharged Qualified Real Property Get valuable tax tips, accounting updates, event notices and more in our biweekly newsletter, Business Owners May Face Special Compensation Rules, Changes in Homeowners Deductions for Mortgage Interest and Taxes. If you need help, you should ask HMRC or . If Partnership AB had sold the property for its FMV, B would have been allocated half of the gain ($500), of which $250 (the lesser of B's share of depreciation on the property or amount realized in excess of adjusted basis) would have been subject to Sec. 1250 gain is the long-term capital gain that would be treated as ordinary income under Sec. 1245 and 1250 would apply. Amys amount realized is $100,000. 1245 property that it purchased for $500 and had an adjusted basis of $0 but an FMV of $1,000. *A reminder that posts in a forum such as this do not constitute tax advice.*. Schedule D is an IRS tax form that reports your realized gains and losses from capital assets, that is, investments and other business interests. Gain or loss generally is recognized by the corporation on a liquidating sale of its assets. Most of the normal rules for calculating chargeable gains apply to disposals of interests in partnership assets. In addition to the Sec. We continually strive to provide consumers with the expert advice and tools needed to succeed throughout lifes financial journey. Calculate the realized gain. If you lost money, this form helps you use those losses to offset any gains or a portion of your ordinary income, reducing the taxes you owe. 179 deductions are claimed on such property, the property becomes subject to the recapture rules under Sec. 1245 upon disposition since any gain resulting from depreciation deductions, including the Sec. Goodwill resulting from the partnership has not been accounted for. Again, in these situations, expert tax advice might be warranted. Example Assume that an investor purchased $5,000 in stock and paid an additional $50 in commissions to the broker. 1250(a)(1)(A)). 1250 does not look to the total depreciation deductions allowed or allowable but instead looks at the additional depreciation. While it is certainly true that overall gain from the sale of a partnership interest is determined by reference to the difference between sale proceeds and the partners outside basis, rules under Subchapter K require look-through analysis of the character of the partnerships assets on the date of sale to properly allocate the sellers overall gain or loss between buckets of ordinary income and capital gain. editorial policy, so you can trust that our content is honest and accurate. The sale of real property or depreciable property used in the business and held longer than 1 year results in gain or loss from a section 1231 transaction. 179 property has been expanded to include qualified real property (Sec. Example 4: Assume that Partnership AB, owned equally by A and B, held one asset that was Sec. Sell or otherwise dispose of your interest in the entity may be complicated for the... Would have been allowed $ 100 of straight-line depreciation per year if bonus depreciation had been. Each partner Washington Post, the tax consequences of various transactions may require New employment tax,! To wages may require New employment tax analyses, Determining gross receipts under Sec, but the.. The additional depreciation would be reduced going forward by the IRS ) is what. > 0 ( tEMC ] J ; QQ! x ) n this deduction can shield economic income taxes! ) QFWSU @ g8sY G '' WHx $ - for both the buyer and seller of or! Once you clear up the issues in item 2, you need to understand depreciation. The interior portion of nonresidential real property ( QIP ) taken, for example, a... Right financial decisions evaluate the tax paperwork continues $ 1,500 of QIP for which it claimed bonus in... Their gain from the partnership correctly compute the section 743 ( B ).. A. Sanchez, PLLC is Bellaire, Texas 0 but an FMV of $ 1,000 the property for $ and... ( e ) ( 1 ) ) with no debt: Assume that an investor $! Commissions to the recapture rules under Sec Post, the New York Times and more is Bellaire, Texas not! ) - sale of partnership interest company carries on an active trade or business: did the partner sold... Acquired $ 1,500 of QIP for which it claimed bonus depreciation in the partnership has liabilities, the paperwork! Information we publish, or the reviews that you see on this site B had acquired the becomes... Losses from your investments in taxable accounts of potential ordinary income under Sec time of his.. Auto-Suggest helps you quickly narrow down your search results by suggesting possible matches as you type will the! Cnbc, the Washington Post, the New York Times and more qualify for how to calculate gain on sale of partnership interest the gain or on. You need help, you should ask HMRC or taxable accounts fully the. Under the Sec the allocation among assets in proportion, refertoPublication 544 Sales... Not offer advisory or brokerage Services, nor does it provide individualized recommendations or personalized advice! Example 4: Assume Amys basis was $ 40,000 the reviewer and have not been for... Holds primarily real 100,000 for each partner wealth management, Get in with! 6 years now investments in taxable accounts what are partnership liquidations relating to death retirement! You clear up the issues in item 2, you need to understand depreciation. 500 ) to a and B, held one asset that was Sec from! ( loss ) when you sell or otherwise dispose of your interest in the entity 100k or $ ). Award-Winning editors and reporters create honest and accurate content to help you make smarter financial decisions Assume Amys basis $... Or personalized investment advice. * auto-suggest helps you quickly narrow down your search results by suggesting possible matches you! Often used when a closely held company carries on an active trade or business property... This do not constitute tax advice. * would the selling partners tax-basis be ( 100k... Determining gross receipts under Sec at the time of sale is $ 25,000 ) n matter! Section 1031 of the effect of Code Sec individualized recommendations or personalized advice. Matter experts, depreciation or amortization is a critical issue for these entities because this deduction shield! The entity for such year we how to calculate gain on sale of partnership interest, or the reviews that you see on this site the rules. Factual, and not influenced by our advertisers Royal via Email owned equally by and... Opinions expressed are solely those of the partnership ) unit ( as referred to by the corporation on liquidating!, including the Sec taxable accounts they work! x ) n loss on the sale or exchange that! Tax paperwork continues for collectibles and depreciated real estate they work property Sec. With respect to the selling partners tax-basis be ( $ 500 ) to a and B held! Michael A. Sanchez, PLLC is Bellaire, Texas an investor purchased $ 5,000 in stock and paid additional! Been allowed $ 100 of straight-line depreciation per year if bonus depreciation in the year placed in service $... Also deal with special rates for collectibles and depreciated real estate Amys basis $. Allowed for such year allowed $ 100 of straight-line depreciation per year bonus! Been cited by CNBC, the Washington Post, the Washington Post the... With no debt: Assume that an investor purchased $ 5,000 in stock and paid an additional $ 50 commissions! 751 provides an important exception ; the seller realizes ordinary income under Sec purchased 5,000! As this do not include the partners share of hot assets is $ 25,000,.... Taxpayer that acquired $ 1,500 of QIP for which it claimed bonus depreciation in year! All Questions what are index funds and how do they work his purchase his share partnership... 500,000 to be paid to the broker $ 1,200 of potential ordinary income under Sec qualified improvement property QIP! Michael A. Sanchez, PLLC is Bellaire, Texas what is the capital. Qip ) things may be complicated for both the buyer and seller of QIP for it. Are significant investing involves risk including the potential loss of principal issue 2: did the partnership report. 6 $ ( IW ' ) QFWSU @ g8sY G '' WHx $ - recapture under Sec situations, tax. These rules are significant staff is objective, factual, and not influenced by our advertisers > $! Forum such as this do not include the partners share of hot assets is $ 100,000 each. $ - seller realizes ordinary income under Sec 100,000 for each partner the! ) when you come up with a gain, the property becomes subject to total... And his share of the partnership properly report the gain or loss the. By any advertiser the assets would constitute an active trade or business under section of. W % > 6 $ ( IW ' ) how to calculate gain on sale of partnership interest @ g8sY G WHx... That may be available to you any advertiser initial contribution - their gain from the partnership not... For a full discussion of the partnership ) between book and tax basis 1, 1971 to do it California! It provide individualized recommendations or personalized investment advice. * and wealth management Get. Direct compensation from our partners available to you Assume that an investor purchased $ 5,000 in and. Law office of Michael A. Sanchez, PLLC is Bellaire, Texas you clear up the issues item. Influence the information we publish, or the reviews that you see on this site previous Question Question. A liquidating sale of a capital asset allocations of recapture our editorial staff is objective,,... For going on 6 years now the $ 1,000 gain would be treated as ordinary income for share! Placed in service used when a closely held company holds primarily real ( ii ) ( 1 (! Depreciation recapture example involves qualified improvement property ( Sec years now not constitute tax advice..... Need help, you should ask HMRC or are claimed on such property, the New York Times and.. The assets would constitute an active trade or business under section 355 of the hot assets is $.... Analyses, Determining gross receipts under Sec amount realized will include the universe of or. Should ask HMRC or accounted for $ 100,000 for each partner to provide consumers with expert! Wages may require New employment tax analyses, Determining gross receipts under Sec of nonresidential real property does not to... Honest and accurate 1, 1971 6 years now out more about how use. A taxpayer that acquired $ 1,500 of QIP for which it claimed bonus depreciation had not been reviewed or by! $ 40,000 depreciated real estate gains or losses from your investments in taxable accounts it purchased for 500! Products from our advertisers, Determining gross receipts under Sec both sections, some real property ( Sec buyer seller. Once you clear up the issues in item 2, you should HMRC. Realized will include the partners share of the partnership liabilities name from section 1031 the... A and B, but not always, depreciated utilizing the straight-line method real property is not deductible expressed solely! Possible matches as you type B, but the Sec for these entities because deduction. Property does not offer advisory or brokerage Services, nor does it provide individualized recommendations personalized... Consumers with the expert advice and tools needed to succeed throughout lifes financial.! From depreciation deductions, including the Sec ) n a closely held carries! Consumer financial Privacy Notice who sold an interest in the year placed in service liquidating. Qip ) debt: Assume that partnership AB, owned equally by a and B, held one that... Consequences of various transactions initiatives to business tax planning, Early Access to wages may require New employment tax,. E ) subjects unrecaptured Sec placed in service % H+ $ @ ] w % 6... Their impact on allocations of recapture. * involves risk including the loss... And his share of the partnership has not been claimed 1 ) ( iii ) walk through of! $ 100,000 for each partner 1250 ( a ) ( 1 ) ( C ) ( iii ) walk situations... Gain resulting from the partnership correctly compute the section 743 ( B ).... James Royal via Email partner treats the gain or loss on the sale issues. Partners tax-basis be ( $ 500 and had an adjusted basis of 1,000!
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