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For purposes of this paragraph (d)(2), money contributed by the distributing partnership does not include any money deemed contributed by the partnership as a result of section 752.Section 731(c) and this section apply to the distribution of a marketable security acquired by the partnership in a nonrecognition transaction in exchange for a security the distribution of which immediately prior to the exchange would have been excepted under this paragraph (d) only to the extent that section 731(c) and this section otherwise would have applied to the exchanged security.Unless otherwise specified, all securities held by a partnership are marketable securities within the meaning of section 731(c); the partnership holds no marketable securities other than the securities described in the example; all distributions by the partnership are subject to section 731(a) and are not subject to sections 704(c)(1)(B), 707(a)(2)(B), 751(b), or 737; and no securities are eligible for an exception to section 731(c). 2657]§ 108 - Income from discharge of indebtedness§ 110 - Qualified lessee construction allowances for short-term leases§ 129 - Dependent care assistance programs§ 132 - Certain fringe benefits§ 148 - Arbitrage§ 149 - Bonds must be registered to be tax exempt; other requirements§ 150 - Definitions and special rules§ 152 - Dependent defined§ 162 - Trade or business expenses§ 163 - Interest§ 165 - Losses§ 166 - Bad debts§ 168 - Accelerated cost recovery system§ 170 - Charitable, etc., contributions and gifts§ 171 - Amortizable bond premium§ 179 - Election to expense certain depreciable business assets§ 179A - Repealed. The examples are as follows: 's interest in the partnership is 0. This is a list of United States Code sections, Statutes at Large, Public Laws, and Presidential Documents, which provide rulemaking authority for this CFR Part. This list is taken from the Parallel Table of Authorities and Rules provided by GPO [Government Printing Office].
The basis of the distributee partner's interest in the partnership is determined under section 733 as if no gain were recognized by the partner on the distribution by reason of section 731(c) and this section.Partnerships allow multiple people to pool their assets together and conduct business.When it comes time to part ways, the partnership distributes its assets back to the partners and dissolves.No adjustment is made to the basis of partnership property under section 734 as a result of any gain recognized by a partner, or any step-up in the basis in the distributed marketable securities in the hands of the distributee partner, by reason of section 731(c) and this section.If a distribution results in the application of sections 731(c) and one or both of sections 704(c)(1)(B) and 737, the effect of the distribution is determined by applying section 704(c)(1)(B) first, section 731(c) second, and finally section 737.
The basis of the distributee partner's interest in the partnership for purposes of determining the amount of gain, if any, recognized by reason of section 731(c) (and for determining the basis of the marketable securities in the hands of the distributee partner) includes the increase or decrease, if any, in the partner's basis that occurs under section 704(c)(1)(B)(iii) as a result of a distribution to another partner of property contributed by the distributee partner in a distribution that is part of the same distribution as the marketable securities.