Part I concludes with a brief discussion of the general anti-abuse regulations. Distribution to Contributing Partner - Section 737 C.

Part II discusses the principles applicable to all distributions — current and liquidating — including distinguishing between them — and the general principles for nonrecognition of gain or loss on distributions of partnership property in kind, and the effect of partnership liability shifts as part of distributions.

Part I, Introduction, briefly discusses important general principles not directly related to distributions, but that will nevertheless frequently be referred to throughout the Portfolio, including partnership capital accounts, §704(c) and reverse §704(c) allocations. Basis of Property Received in a Current Distribution 1.

partnership liquidating distribution detailed example-31partnership liquidating distribution detailed example-90partnership liquidating distribution detailed example-57

Insurance Payable to Partnership (Funded Buy-Out) 4.

Judicially Created IRD Working Papers Table of Worksheets Worksheet 1 Excerpts from House Ways and Means Committee Report to H.

Distributions, usually liquidating distributions, are important components of major partnership restructurings, including divisions, mergers, incorporations, and changes in legal form. Transfers After December 14, 1999 (1) Allocations Between Asset Classes (2) Allocations Within Asset Classes (3) Increases (4) Decreases (5) Special Rule for Stock of Corporate Partners: 755(c) (6) Requirement that Difference Between Value and Basis Be Reduced b. Timing of Basis Adjustments Caused by Liquidation of Partner's Interest 4.

As with all other aspects of partnership taxation, the dual nature of a partnership for tax purposes — as at times an aggregation of its partners, and at times an entity — complicates the discussion, particularly because no one, including the author, has been able to articulate a comprehensive statement of when the aggregate, and when the entity, aspect should predominate.

Worksheet 3 Excerpt from Committee on Ways and Means, U.

Worksheet 4 Excerpt from Senate Report of the Committee on Finance on H.

Worksheet 7 Omnibus Budget Reconciliation Act of 1993 Conference Report Section 13206(e) - Definition of “Substantially Appreciated” Inventory (P. Worksheet 7B Taxpayer Relief Act of 1997 Worksheet 8 ABCD Partnership Agreement (Liquidation Article).

Worksheet 7A General Agreement on Tariffs and Trade, Section 741 of the Revenue Provisions (Title VII), Relating to Partnership Distributions (Act Language and Technical Explanation) (1994).

Even the general partnership can achieve most of these characteristics by a carefully drafted partnership agreement.