Partnership property transactions: exploring the limits of Secs. 704(c) and 707(a)(2).: An article from: The Tax Adviser
Book Details
Author(s)Robert C. Ricketts
PublisherAmerican Institute of CPA's
ISBN / ASINB0008VCPBS
ISBN-13978B0008VCPB8
AvailabilityAvailable for download now
Sales Rank14,321,327
MarketplaceUnited States 🇺🇸
Description
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on February 1, 1993. The length of the article is 5038 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The Deficit Reduction Act of 1984 enacted IRC 707(a)(2) to prevent abuse of subchapter K partnership property transfers that were attempts to disguise sales. The Omnibus Budget Reconciliation Act of 1989 altered IRC 704(c)(1)(B) to force the recognition of loss or gain by any partner contributing to the partnership on the date the contribution is made. Congressional intent gives 707(a)(2) precedence over 704(c)(1)(b), but may permit like-kind distributions to be made under IRC 704(c)(2) which requires that the transfers must be within 180 days of each other and qualify as alike-kind distribution.
Citation Details
Title: Partnership property transactions: exploring the limits of Secs. 704(c) and 707(a)(2).
Author: Robert C. Ricketts
Publication:The Tax Adviser (Magazine/Journal)
Date: February 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n2 Page: 80(6)
Distributed by Thomson Gale
From the supplier: The Deficit Reduction Act of 1984 enacted IRC 707(a)(2) to prevent abuse of subchapter K partnership property transfers that were attempts to disguise sales. The Omnibus Budget Reconciliation Act of 1989 altered IRC 704(c)(1)(B) to force the recognition of loss or gain by any partner contributing to the partnership on the date the contribution is made. Congressional intent gives 707(a)(2) precedence over 704(c)(1)(b), but may permit like-kind distributions to be made under IRC 704(c)(2) which requires that the transfers must be within 180 days of each other and qualify as alike-kind distribution.
Citation Details
Title: Partnership property transactions: exploring the limits of Secs. 704(c) and 707(a)(2).
Author: Robert C. Ricketts
Publication:The Tax Adviser (Magazine/Journal)
Date: February 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n2 Page: 80(6)
Distributed by Thomson Gale
