Chief Counsel Advisory 2006-50014
Partnership distribution in redemption of Taxpayer's interest
Internal Revenue Service (I.R.S.)
Chief Counsel Advisory (CCA)
Issue: December 15, 2006
September 7, 2006
Section 701 - Partners, Not Partnerships, Subject to Tax
Section 732 - Basis of Distributed Property Other Than Money
To: Kelly Davidson, Attorney Advisor John Duncan, Attorney Advisor Large & Mid-Size Business
From: Christine Ellison, Chief, Branch 3 (Passthroughs & Special Industries)
Subject: Application of Sections 731 and 732 to property acquired by a partnership solely for purposes of distribution in liquidation to a retiring partner.
This Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as precedent.
Whether a distribution purportedly in redemption of Taxpayer's interest in Partnership included the State Y house purchased by Partnership.
The non-recognition provision of §
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