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Sales and Exchanges of Partnership Interests
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acquiring corporation acquisition adjusted basis alternative minimum tax applies assets-over basis adjustment Bittker capital gain cash COD income Commissioner continuity of interest CONTRIBUTED PROPERTY controlled corporation corporate tax shelters corporation stock corporation's decrease deductions deemed sale deficit restoration obligation depreciation determining discharge of indebtedness discharged debt dividend election excluded discharge fair market value full paragraph gain or loss gross income holding period increase indebtedness income insert Internal Revenue Code inventory items issued liquidation LPRS nonqualified preferred stock nonrecognition nonrecourse debt offset operating losses ordinary income partner partnership agreement partnership interest Peracchi percent promissory note proposed regulations reduced reorganization resulting partnership REVENUE RULING sale or exchange section 351 selling share shareholder's shareholders special allocations subchapter S corporation suspended losses target corporation tax attribute reduction tax consequences Tax Court tax-free taxable income Taxation Taxpayer Relief Act terminating partnership transaction transferred treated unrealized receivables