Technical topics regarding tax preparation.
8-May-2018 11:15am
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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?
8-May-2018 2:22pm
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There is no partnership left to make a 754 election.
8-May-2018 2:38pm
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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?
8-May-2018 3:21pm
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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.
8-May-2018 4:30pm
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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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