...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...

...or to be delivered, to the extent that the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or (i1) Services rendered or to be rendered. (c) Adjustments for liabilities, etc. In making the adjustments...

...inserting in lieu thereof "ordinary income". (C) Section 707 (b) (2) is amended by striking out "as gain from the sale or exchange of property other than a capital asset" and inserting in lieu thereof "as ordinary income". (D) Paragraphs (1) and (2) of section 735(a) are...

...or to be delivered, to the extent that the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or (c) ADJUSTMENTS FOR LIABILITIES, ETC.—In making the adjustments to the earnings and profits of...

...transferor partner in exchange for all or a part of his interest in the partnership attributable to — (ll unrealized receivables of the partnership, or (2)...or exchange of property other than a capital asset. "S. Kept. 1622. 83d Cong., 2d Sess. 98 (1954); H. Kept. 1337, 83d Cong., 2d Sess. 70 (19541. 683 CHARLES...

...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 (B) services rendered or to be rendered. (c) PRESUMPTION IN CURTAIN CASES. — (1) IN GENERAL. —...

...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 (ii) services rendered, or to be rendered. Under section 751(c) "unrealized receivables" also includes...

...delivered, or to be delivered, to the extent that proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset. 2. Services rendered, or to be rendered. The same subsection goes on to state that items that generate...

...receivables received by the partner in a distribution from a partnership is considered gain or loss from the sale or exchange of property other than a capital asset. (Reg. § 1.735-1 (a) (1)) Inventory Items Any gain realized or loss sustained by a partner on a sale...

...provides for a payment with respect to good will. SBC. 761. UNREALIZED RECEIVABLES AND INVENTORY ITEMS. (a) SALE OB EXCHANGE OF INTEREST IN PARTNERSHIP. —...or exchange of property other than a capital asset. (b) CERTAIN DISTRIBUTIONS TREATED AS SALES OB EXCHANGES. — (1) GENERAL BULK. — To the extent a...