721(b) did not apply; thus, the taxpayers would have no recognized gain or loss on the transfer to the partnership.
705 final regulations (20) that provide guidance when (1) a corporation owns a direct or indirect interest in a partnership that owns the corporation's stock, (2) the partnership distributes money or other property to another partner who recognized gain or loss on the distribution during a year the partnership did not have a Sec.
When a partner withdraws from a partnership, the transaction generally comes under the subchapter K provisions as a sale or exchange of a capital asset so that any
recognized gain or loss is characterized as capital in nature (except to the extent that Sec.