Liquidating distribution partnership basis
Tax Treatment of Partnership Distributions IRC Sec.
If the corporation distributes appreciated property, the corporation is taxed on the gain under Code § 311(b).But that section only covers gain on distributions of appreciated property. If the corporation distributes property that has depreciated (i.e., property with a built-in loss), Code § 311(b) does not apply. 12 (2/16/93) states the Internal Revenue Service's position on the special basis adjustment available to partnerships under IRC Sec.
734 basis adjustment precisely when the partnership acquires a legal obligation for future liquidation payments entailing a fixed amount and timing. 734(b) in connection with certain deferred liquidation payments to a retiring partner or a deceased partner's successor.Only Partner C recognizes a gain on the distribution (,000) since she received cash in excess of her partnership basis.