Question
The ABCDE partnership had the following occur: 11/30/2014 A died and left her 20% interest to G. 1/1/2015 B gave his interest to H. The
The ABCDE partnership had the following occur:
11/30/2014 A died and left her 20% interest to G.
1/1/2015 B gave his interest to H. The partnership does not have any debt.
3/1/2015 C contributed her 20% interest to the C corporation in a tax-free exchange.
6/1/2015 D sold his 20% interest to E.
12/31/2015 A new partner, F, was allowed into the partnership with a 1/6 interest in capital and profits.
Which of these constitutes a sale or exchange of a partnership interest under Code Section 708, and is there an actual termination of the partnership for tax purposes?
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