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A. Explain the principles and consequences of a disguised sale in the contribution of property to a partnership. B. What is a rebuttable presumption and
A. Explain the principles and consequences of a "disguised sale" in the contribution of property to a partnership.
B. What is a "rebuttable presumption" and the "substance over form" doctrine?
C. How do you structure a transaction so that there is a rebuttable presumption against the transaction being challenged by the IRS as a disguised sale?
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