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

A, B and C are equal partners in the ABC partnership. The partnership had elected 754, which it belatedly realized was a mistake. On January 1, the partnership decided to split the organization into the AB and BC partnerships which are equal as to profits, losses and capital. What are the tax consequences of the division?