DATC: Recapture of Accelerated/accrued Deductions on HUD Involved Housing Study of the Deferred Adverse Tax Consequences Program

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Department of the Treasury, Internal Revenue Service, 1984 - Capital gains tax
 

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Page 14 - For purposes of this section, a liability to which property is subject shall, to the extent of the fair market value of such property, be considered as a liability of the owner of the property.
Page 14 - In the case of a sale or exchange of an interest in a partnership, gain or loss shall be recognized to the transferor partner. Such gain or loss shall be considered as gain or loss from the sale or exchange of a capital asset, except as otherwise provided in section 751...
Page 14 - Increase in partner's liabilities. An v increase In a partner's share of the liabilities of a partnership, or any Increase in a partner's Individual liabilities by reason of the assumption by such partner of partnership liabilities, shall be considered as a contribution of money by such partner to the partnership.
Page 15 - Limited Partnerships and Tax Shelters: The Crane Rule Goes Public,
Page 41 - The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Page 14 - Decrease in partner's liabilities. Any decrease in a partner's share of the liabilities of a partnership, or any decrease in a partner's individual liabilities by reason of the assumption by the partnership of such individual liabilities, shall be considered as a distribution of money to the partner by the partnership.
Page 16 - A's original liability of $150 now attributable to partners B and C and reflected in their bases under the provisions of paragraph (a) of this section. (c) Liability to which property is subject. Where property subject to a liability is contributed by a partner to a partnership, or distributed by a partnership to a partner, the amount of the liability, to an extent not exceeding the fair market value of the property at the time of the contribution or distribution, shall be considered as a liability...
Page 41 - Although a different approach might have been taken with respect to a nonrecourse mortgage loan, the Commissioner has chosen to accord it the same treatment he gives to a recourse mortgage loan. The court approved that choice in Crane and the respondents do not challenge it here. The choice and its resultant benefits to the taxpayer are predicated on the assumption that the mortgage will be repaid in full.
Page 41 - Obviously, if the value of the property is less than the amount of the mortgage, a mortgagor who is not personally liable cannot realize a benefit equal to the mortgage.
Page 15 - When a partnership interest is sold or exchanged, the general rule for the treatment of the sale or exchange of property subject to liabilities will be applied.

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