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Is the price purchased for the company not deductible, outside basis, till they close the company or re-sell it. The tax payer purchased the company not just the assets, so it is just a change of ownership as far as the company is concerned. Can the access price be amortized as goodwill over 15 years as an attachment to his K-1, for his outside basis
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Look at the details of the purchase agreement to determine what you bought, also look carefully at the IRS 8594 that you filed for the sale. It should give you a substantive basis to make the deductions you want.
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Is the 8594 filed with the 1065 since it is the new member who is purchasing the whole company, not just the assets, in order to use the step up basis election.
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Purchase is just like buying stock. Since you mentioned 1065: Don't forget B-1 and 8308. How many partners?
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The new owners will be a total of three. Thanks for the feedback!
