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http://worldcat.org/entity/work/id/62737394

Partnership transactions--section 751 property

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  • "Section 751 property"@en
  • "Tax management portfolios"
  • "Tax management"

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description

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  • ""... analyzes the federal income tax consequences of (1) a sale or exchange of a partnership interest where the partnership owns a [section] 751(a) property (i.e., unrealized receivables and inventory items) and (2) a distribution from a partnership owning [section] 751(b) property (i.e., unrealized receivables and inventory items which have appreciated substantially in value) where such distribution has the effect of changing the proportionate interests of the partners in the [section] 751(b) property. Sale of a partnership interest generally gives the selling partner capital gain. Section 751, however, recharacterizes a portion of the amount realized as ordinary income to the partner, at times even in the absence of realized gain. The amount so recharacterized roughly corresponds to the amount of ordinary income the partnership would have if it sold the [section] 751(a) property, thus preventing a partner from converting into a capital gain the ordinary income that would pass through if the partnership sold the property. ""

name

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  • "Partnership transactions -- section 751 property"
  • "Partnership transactions--section 751 property"@en
  • "Partnership transactions--section 751 property"

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