Liquidating distribution from partnership

The provisions of this paragraph may be illustrated by the following examples: Partner A, with an adjusted basis of ,000 for his partnership interest, receives in a current distribution property having an adjusted basis of ,000 to the partnership immediately before distribution, and ,000 cash.

The basis of the property in A's hands will be ,000.

If the required decrease exceeds the amount of unrealized depreciation in the distributed property, the excess is allocated to the distributed property in proportion to the adjusted bases of the distributed property, as adjusted pursuant to the immediately preceding sentence.

Any increase to the basis of distributed property required under paragraph (c)(1)(ii) of this section is allocated first to distributed property (other than unrealized receivables and inventory items) with unrealized appreciation in proportion to each property's respective amount of unrealized appreciation before any increase (but only to the extent of each property's unrealized appreciation).

He receives a current distribution of ,000 cash and property with an adjusted basis to the partnership of ,000.



The basis of property (other than money) received by a partner in a distribution from a partnership, other than in liquidation of his entire interest, shall be its adjusted basis to the partnership immediately before such distribution.However, the basis of the property to the partner shall not exceed the adjusted basis of the partner's interest in the partnership, reduced by the amount of any money distributed to him in the same transaction.


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