The proposed bonus depreciation regulations provide that a transferee partner is able to claim used bonus depreciation on the 754 step-up (at least for the portion of property the partner has never used before). To do this, the taxpayer must meet the purchase requirements of section 179(d). Since this is allowed, the purchase requirements of section 179 must not generally prohibit section 179 on 754 step-ups. But, unlike with the proposed section 168 regs, there is no specific provision limiting this to portion of the property not previously used by the transferee. We could infer that the same rule applies, but I'm not sure.
-Brian
Director of Tax Accounting Methods & Credits
SourceAdvisors.com
Opinions my own.