Question
In a full or partially liquidating distribution of a partner's interest involving Section 751 assets and Other Property, what is required if the partner does
In a full or partially liquidating distribution of a partner's interest involving Section 751 assets and Other Property, what is required if the partner does not receive a proportionate shares of Section 751 property and Other Property in the liquidating distribution?
1. The required procedure follows the normal liquidating distribution rules..
2. The required procedure results in a fully taxable exchange between the partnership and the partner.
3. The partnership and the partner are involved in a phantom taxable exchange of properties after the partner takes a "phantom distribution" of property from the partnership. Gains could be recognized by the partner and the partnership in this exchange.
4.A tax penalty is levied on the partnership
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