WHAT ARE IRC SECTION 751 ASSETS

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Under IRC Section , when a partner sells his interest, he is entitled to capital gain treatment, except as provided in IRC Section

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partnership property (including money) other than property described in subparagraph (A)(i) or (ii) in exchange for all or a part of his interest in partnership.

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With a Section Transfer, we are usually talking about a commercial building or an appreciable asset. For this article, we are going to stick.

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nd, Partnership Transactions—Section Property, analyzes the federal income tax consequences of (1) a sale or exchange of a partnership interest.

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The “hot asset” re-characterization provisions of IRC frequently result of Section property subject to ordinary income reclassification.

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In , Section was passed to “prevent the conversion of potential ordinary income into capital gain by virtue of transfers of partnership.

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Cf I.R.C. § (c)(1)(A)(i) (limiting basis of distributed hot asset to basis in partnership's hands). 26The only example in the section regulations illustrating.

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ABC holds hot assets, otherwise referred to as Sec. property or ordinary income property. A's outside basis of his interest in ABC is $, He sells his .

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(a) Sale or exchange of interest in partnership. The amount of any money, or the fair market value of any property, received by a transferor partner in exchange.

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