One partner for one day

2 equal partners A and B. Partner B sells his entire interest to partner A on 12/31/2018. Partner C purchases a 25% interest from partner A (the remaining partner) on 01/01/2019. Does the partnership still exist for tax purposes into 2019 after the 12/31/2018 sale?

I would argue, yes.

The morning of 12/31/2018 there were two partners. At the end of the day 1/1/2019, there were two partners. There is never a full day without two partners.

My problem is the wording in 708(b)(1):

"A partnership terminates when the operations of the partnership are discontinued and no part of any business, financial operation, or venture of the partnership continues to be carried on by any of its partners in a partnership."

"partners in a partnership" I was thinking that there are no longer any partners in a partnership. I agree with you Capt, that a day did not exist without two partners, so I think it remains active.

And what's the profit look like for one day, Jan. 1? Unless you're selling champagne and party favors, I expect 0.

My problem is the wording in 708(b)(1):

"A partnership terminates when the operations of the partnership are discontinued and no part of any business, financial operation, or venture of the partnership continues to be carried on by any of its partners in a partnership."

I think this supports my position. The operations of the partnership continue without disruption AND there continues to be partners doing the carrying out.