Research

Use the research material available under the Authoritative Literature tab to answer the following question. $($See Research Task$-$Based Simulations for instructions.$)$

Andrea and Buffy formed a partnership in June and began operations on September $1.$ They are considering the merger of their partnership with another partnership and thereby forming one partnership, and are interested in learning more about the tax issues associated with such a merger. What IRC subsection states that if two or more partnerships merge or consolidate into one partnership, the resulting partnership shall be considered a continuation of the merging or consolidating partnership the members of which own an interest of more than $50\%$ in the capital and profits of the resulting partnership?

IRC

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Examples of correctly formatted IRC responses are IRC $1($a$),$ IRC $56($a$),$ IRC $162($a$),$ IRC $263$A$9($a$),$ IRC $1245($a$),$ IRC $2032$A$($a$),$ and IRC $1400$Z$-1($a$).$