Source: Federal Income Tax: Code and Regulations-Selected Sections (2020-2021), by Robert J. Peroni, published by Wolters Kluwer July 30, 2020. ISBN 9780808054610. Product Number 10014873-0011

The AB an CD partnerships merged on September 30. What are the tax consequences under the following alternative circumstances?

1. After the merger, each partner owns a 25 percent capital and profits interest.
2. After the merger, A and B each owns a 15 percent capital and profits interest and C and D each owns a 35 percent interest.