# Treas. Reg. § 1.346-3: Effect of certain sales.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-1.346-3>. Interprets 26 U.S.C. § 346.

The determination of whether assets sold in connection with a partial liquidation are sold by the distributing corporation or by the shareholder is a question of fact to be determined under the facts and circumstances of each case.