Question

Fern, Inc., Ivy, Inc., and Jeremy formed a general partnership. Fern owns a 50% interest, and Ivy and Jeremy each own 25% interests. Fern, Inc. files its tax return on an October 31 year end; Ivy, Inc. files with a May 31 year end, and Jeremy is a calendar year taxpayer. Which of the following statements is true regarding the taxable year the partnership can choose?

a. The partnership must choose the calendar year because it has no principal partners.
b. The partnership must choose an October year-end because Fern, Inc., is a principal partner.
c. The partnership can request permission from the IRS to use a March 31 fiscal year under § 444.
d. The partnership must use the "least aggregate deferral" method to determine its taxable year.
e. None of the above.

Answer 1

d. The partnership must use the "least aggregate deferral" method to determine its taxable year.

Step-by-step explanation:

The least
`\text{aggregate }` deferral of income may be obtained by multiplying the LCC profit of every member for a year by the
`\text{number of months}` of the deferral which would arise through the selection of a proposed year end.

They must this method as the
`\text{partnership}` does not have any
`\text{majority partners}` and all the principal partners do not have same taxable year. The least
`\text{aggregate }` deferral method determines the required
`\text{taxable year}` of the partnership.

Thus, the correct option is (d).