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1 Chapter 10: Special Partnership Issues
SPECIAL PARTNERSHIP ISSUES (1 of 2) Nonliquidating distributions §751 assets Liquidating distributions Sale of partnership interest Retirement or death of a partner ermination of a partnership 2
2 SPECIAL PARTNERSHIP ISSUES(1 of 2) Nonliquidating distributions §751 assets Liquidating distributions Sale of partnership interest Retirement or death of a partner Termination of a partnership
SPECIAL PARTNERSHIP ISSUES (2 of 2 Optional basis adjustments Special forms of partnerships Electing large partnerships 3
3 SPECIAL PARTNERSHIP ISSUES(2 of 2) Optional basis adjustments Special forms of partnerships Electing large partnerships
Nonliquidating Distributions General rules Precontribution gain Basis effects of distributions Holding period and character of distributed property
4 Nonliquidating Distributions General rules Precontribution gain Basis effects of distributions Holding period and character of distributed property
General rules No gain or loss by either partner or partnership Money "distributions in excess of partner's basis triggers capital gain recognition by partner Money" includes cash, reduction of partner's liabilities, FMV of securities 5
5 General Rules No gain or loss by either partner or partnership “Money” distributions in excess of partner’s basis triggers capital gain recognition by partner “Money” includes cash, reduction of partner’s liabilities, FMV of securities