Par. 4. Section 1.704-3 is amended in paragraph (a)(9) by adding a sentence immediately following the first sentence to read as follows:
(a) * * *
(9) * * * If a partnership (the upper-tier partnership) owns an interest in another partnership (the lower-tier partnership), and both the upper-tier partnership and the lower-tier partnership simultaneously revalue partnership property pursuant to § 1.704-1(b)(2)(iv)( f ), the principles of this paragraph (a)(9) shall apply to any reverse section 704(c) allocations created upon the revaluation. * * *
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