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Liquidating distribution from partnership

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The partnership is liquidated and non cash assets are sold for 100,000.

The non cash assets of 140,000 are sold for 100,000 making a loss on sale of 40,000.

liquidating distribution from partnership-19liquidating distribution from partnership-47

a partnership shall be treated as engaged in any trade or business engaged in by, and as holding (instead of a partnership interest) a proportionate share of the assets of, any other partnership in which the partnership holds a partnership interest, and If the preceding sentence does not apply under such regulations with respect to any interest held by a partnership in another partnership, the interest in such other partnership shall be treated as if it were specified in a subclause of clause (i). 105–34 substituted “section 751(d)” for “section 751(d)(2)”.

It is not guaranteed to be accurate or up-to-date, though we do refresh the database weekly.

Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion. This list is taken from the Parallel Table of Authorities and Rules provided by GPO [Government Printing Office].

A major difference between partnerships and S corpo­rations involves the treatment of distributions of ap­preciated property.

With respect to the timing of gain recognition from such distributions, the rules applicable to partnerships (unlike those applicable to S corporations) generally permit gain deferral.