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" The amount of any money, or the fair market value of any property, received by a transferor partner in exchange for all or a part of his interest in the partnership attributable to... "
Reports of the Tax Court of the United States - Página 28
por United States. Tax Court - 1974
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United States Code, Volume 2

United States - 1964 - 1098 páginas
...delivered, or to be delivered, to the extent the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or (2) services rendered, or to be rendered. For purposes of this section and sections 731, 736, and...
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The Code of Federal Regulations of the United States of America

1966 - 396 páginas
...751. Unrealized receivables and inventory items—(a) Sale or exchange of interest in partnership. The amount of any money, or the fair market value...or exchange of property other than a capital asset. (b) Certain distributions treated as sales or exchanges—(1) General rule. To the extent a partner...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1971 - 748 páginas
...751. Unrealized receivables and inventory items — (a) Sale or exchange of interest in partnership. The amount of any money, or the fair market value...or exchange of property other than a capital asset. (b) Certain distributions treated as sales or exchanges — (1) General rule. To the extent a partner...
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The Code of Federal Regulations of the United States of America

1976 - 536 páginas
...the partnership, or (3) Inventory items of the partnership which have appreciated substantially 1» value, shall be considered as an amount realized from...or exchange of property other than a capital asset. 51.751-1 (b) Certain distribution* treated at r exchange* — (1) General rule. To the eimt a partner...
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The Code of Federal Regulations of the United States of America

1995 - 738 páginas
...substantially appreciated inventory items, the money or fair market value of the property received shall be considered as an amount realized from the...or exchange of property other than a capital asset. The remainder of the total amount realized on the sale or exchange of the partnership interest is realized...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1999 - 740 páginas
...substantially appreciated inventory items, the money or fair market value of the property received shall be considered as an amount realized from the...or exchange of property other than a capital asset. The remainder of the total amount realized on the sale or exchange of the partnership interest is realized...
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The Code of Federal Regulations of the United States of America

1990 - 676 páginas
...substantially appreciated inventory items, the money or fair market value of the property received shall be considered as an amount realized from the...or exchange of property other than a capital asset. The remainder of the total amount realized on the sale or exchange of the partnership interest is realized...
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The Code of Federal Regulations of the United States of America

1967 - 408 páginas
...of § 1.751-1) received by him in a distribution from a partnership shall be considered gain or loss from the sale or exchange of property other than a capital asset. (2) Inventory items. Any gain realized or loss sustained by a partner on a sale or exchange of inventory...
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Code of Federal Regulations: Containing a Codification of Documents of ...

2000 - 792 páginas
...in section 751(d)(2)) received in a distribution from a partnership shall be considered gain or loss from the sale or exchange of property other than a capital asset if such inventory items are sold or exchanged within 5 years from the date of the distribution by the...
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Technical Amendments to Internal Revenue Code: Hearings Before a ...

United States. Congress. House. Committee on Ways and Means, United States. Congress. House. Committee on Ways and Means. Subcommittee on Internal Revenue Taxation - 1956 - 520 páginas
...property "with respect to which the amount realized on a sale or exchange by the partnership would be considered as an amount realized from the sale...exchange of property other than a capital asset." This language was designed with the thought of preventing the contribution to a partnership of section...
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