ABCD partnership, a calendar-year partnership, has four owners: A owns a 20 percent interest; B a 25 percent interest; C a 40 percent interest; and D the remaining 15 percent interest. Some of the partners have been having difficulty working with each other, so, with partnership agreement, D sells his 15 percent interest to F on October 20, year 1; B sells her interest to G on January 15, year 2; and C sells his interest to H on December 1, year 1.

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