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§ 1.751-1(a)(3) Worksheet 6 Sample - Statement To Be Attached to the Tax Return of a Partnership Pursuant to Regs.
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In 2014, Dudley contributed land to the Prosperity LLC. The fair market value at the contribution date was 5,000. 720-2nd, Partnership Transactions—Section 751 Property, analyzes the federal income tax consequences of (1) a sale or exchange of a partnership interest where the partnership owns a §751(a) property (i.e., unrealized receivables and inventory items) and (2) a distribution from a partnership owning §751(b) property (i.e., unrealized receivables and inventory items which have appreciated substantially in value) where such distribution has the effect of changing the proportionate interests of the partners in the §751(b) property. Partnership Distributions of Partnership Interests 6. Partnership Mergers, Consolidations, Divisions, and Conversions a. Review of Overall Results of the Application of § 751(b) F. Step 2: Classify Each Partnership Asset Subject to § 751(b) as an Item of § 751(b) Property or an Item of Other Property 4.
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