Cases: Commissioner v. Tufts, 461 U.S. 300 (1983); Marriott International Resorts v. United States, 586 F.3d 962 (Fed. Cir. 2009); Kornman & Associates v. United States, 527 F.3d 443 (5th Cir. 2008)
Forms: Form 8275
Final rules 9
(a) Increase in partner’s liabilities Any increase in a partner’s share of the liabilities of a partnership, or any increase in a partner’s individual liabilities by reason of the assumption by such partner of partnership liabilities, shall be considered as a contribution of money by such partner to the partnership.
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(b) Decrease in partner’s liabilities Any decrease in a partner’s share of the liabilities of a partnership, or any decrease in a partner’s individual liabilities by reason of the assumption by the partnership of such individual liabilities, shall be considered as a distribution of money to the partner by the partnership.
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(c) Liability to which property is subject For purposes of this section, a liability to which property is subject shall, to the extent of the fair market value of such property, be considered as a liability of the owner of the property.
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(d) Sale or exchange of an interest In the case of a sale or exchange of an interest in a partnership, liabilities shall be treated in the same manner as liabilities in connection with the sale or exchange of property not associated with partnerships.