Thanks for the input, @Anonymous & @Critter-3 . Mom is hoping not to hire this out since dad's share was only 1% of the partnership and not significant in value, though may have to resign to doing so.
With respect to the trust, the trust held the 1% interest prior to grantor's death and there is no provision specifically enumerated for the LLC interest in the trust agreement or the LLC operating agreement. Mom becomes the successor trustee and has discretion to administer assets for benefit of herself and their children. So I believe the trust still holds the LLC interest with mom as successor trustee.
With respect to the partnership, not electing 754 as it's not material, and her plan is to liquidate the trust and partnership interest.
Does that simplify things hopefully? Thanks for the guidance on pro rata allocation of income (loss). So that leaves the question regarding the LLC interest being held by the revocable trust and subsequently the irrevocable trust after the grantor's death. How is that "transfer" treated and reported on the 1065? Is that a question that can be answered based on the facts stated above?
