Basis Rules After Technical Termination of Partnership

Article Abstract:

The Internal Revenue Service ruled that where a purchase of assets in an entity whose assets included more than 50% interest in a partnership is treated as a complete liquidation of the partnership, the basis rules of the Internal Revenue Code applied to a deemed distribution.

Purchasing

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REIT's Share of a partnership's Income was Rent Under Seciton 856(d)(1)

Article Abstract:

The Internal Revenue Service ruled that operating agreements by a partnership electing to be taxed as real estate investment trust were to be considered as lease arrangements and that income derived therefrom was to be considered rent under the Internal Revenue Code.

Contracts, Income, Rents (Property)

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Partner Properly Increased His Basis in His Partnership Interest

Article Abstract:

When a partnership's remaining liability was discharged and its partners realized a discharge of indebtedness income, it increased his basis in the partnership interest.

Extinguishment of debts, Debt cancellation

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