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Formation of the Partnership
TABLE OF INTERNAL REVENUE
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acquiring corporation affiliated group allocated amended amount apply basis increase beneficiary Blackacre capital account capital assets carryover paragraph cash Commissioner continuity of interest contributed property controlled corporation corporation shareholders corporation stock corporation's debt deficit restoration obligation depreciation distributing corporation distributive share dividend economic effect electing large partnership entity excluded COD income fair market value Greenacre gross income indebtedness Interhotel Internal Revenue Service inventory items of income liabilities liquidation LPRS negative basis adjustment Nonrecourse Debt ordinary income paragraph and insert partner's basis partner's share partnership interest partnership's assets passive loss Peracchi percent petitioner potential reorganization prior private letter ruling Prop proportionate fair proposed regulations provides pursuant QSST recognize gain reduced respect result Rev.Rul rules second full paragraph section 351 small business trust stockholders subsidiary T.C. Memo target corporation taxable income taxpayer tion transaction transfer transferee partner's Treas treated unrealized receivables Whiteacre X Corp