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Practice Test 3

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Q1

CD LLC is a multi-member limited liability company that began operations in Year 1 and did not file Form 8832 to elect corporate treatment. The LLC has two members: C (60%) and D (40%), and the operating agreement allocates all ordinary income 50/50 regardless of ownership percentage. The LLC generated $200,000 of ordinary business income in Year 1 and no special allocations were supported by substantial economic effect. How should the $200,000 be allocated for federal tax purposes under the partnership allocation rules of Internal Revenue Code section 704(b)?

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