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Sales and Exchanges of Partnership Interests
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15 percent 50 percent adjusted tax basis allocated assets-over partnership merger automobile dealership brand Y automobile business A assets business purpose capital accounts carryover paragraph cash continuing partnership contributed property contributing partner contribution of Asset corporation in exchange Corporation O stock different business distributing corporation distribution of Asset double taxation end of footnote entity exchange for stock excludable dividends fair market value gain in Asset gain or loss income tax insert limited liability company liquidation long-term capital gains merger or consolidation ordinary income partnership interest precontribution gain previously taxed products business proposed regulations provides pursuant qualified dividend income rate reduction recognize gain redemption reduced reorganization retail shoe store retained earnings revaluation Revenue Ruling second corporation Section 306 stock Service has issued shareholders shares of Corporation shoe store business sole proprietorship stock or securities target corporation tax rate taxable taxpayers trade or business transaction transferor partnership treated