Sec 754

Technical topics regarding tax preparation.
#1
zl28  
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There are 3 members in a Partnership.

2 are leaving and the remaining partner is buying them out.

The entity by default will become a single member LLC.

Is there any Sec 754 under this scenario?
 

#2
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There is no partnership left to make a 754 election.
 

#3
zl28  
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that's what i was thinking but not sure...thank you.

so if he was going to add partners...now would be a good time to do so...(before the partnership is dissolved)

so he could get a 754?
 

#4
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He doesn't need a 754. His basis in the property will be what he paid for it. The partnership will be deemed to make a liquidating distribution immediately after the purchase, and the members basis in the partnership will be his new basis in the distributed assets. See Rev Ruling 99-6.
 

#5
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...Rev Ruling 99-6, a copy of which can be found here: https://www.irs.gov/pub/irs-drop/rr-99-6.pdf ;)
 


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