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Research Assignment

Sanchez purchased raw land three years ago for $1,500,000 to develop into lots and sell
to individuals planning to build their dream homes. Sanchez intended to treat this
property as inventory, like his other development properties. Before completing the
development of the property, however, he decided to contribute it to RGV Investors LLC
when it was worth $2,500,000, in exchange for a 10 percent capital and profits interest.
RGV’s strategy is to hold land for investment purposes only and then sell it later at a
gain.
a. If RGV sells the property for $3,000,000 four years after Sanchez’s contribution,
how much gain or loss is recognized and what is its character? {Hint: See § 724.}
b. If RGV sells the property for $3,000,000 five and one-half years after Sanchez’s
contribution, how much gain or loss is recognized and what is its character?

Note: Use proper internal tax research written communication format (see below). I recommend
you keep it to no more than one page, 12 font size, word document. If you have taken the tax
research course and format is slightly different, I will accept that format. Otherwise, you can use
the following research format:

Facts (restatement of scenario):

Issue (tax question(s)):

Findings/discussion as it relates to question “a” (including citation references and final answer as
it relates to this question should be clear and located in the last paragraph/sentence:

Findings/discussion as it relates to question “b” (including citation references and final answer as
it relates to this question should be clear and located in the last paragraph/sentence:

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