- 14 - paragraph (b) of section 1.743-1.[9] [Citations omitted.] Upon a distribution of partnership property, each partner’s basis in his partnership interest is allocated among the distributed assets in proportion to the assets' respective bases to the partnership. Sec. 732(b) and (c). The partnership's bases in its assets may be adjusted under section 743(b) before the partnership distribution to reflect changes in the fair market value of partnership property in relation to the partnership's adjusted bases in the assets. The partnership’s basis, after being adjusted in accord with section 743(b), is then used to allocate basis among the distributed assets. Upon recontribution of the property to the new partnership, the partnership takes the partner's basis in the property at the time of contribution. Sec. 723. In this case, a section 708(b) constructive termination would have occurred due to the sale of more than a 50-percent partnership interest. The assets of Bowlen I, including the Broncos franchise and professional football player contracts, would be deemed to have been distributed to Bowlen and Adams and recontributed to a new partnership. Sec. 1.708-1(b)(1)(iv), 9 Sec. 1.708-1(b)(iv), Income Tax Regs., was amended by T.D. 8717, 1997-24 I.R.B. 5 (May 8, 1997), to apply to sec. 708 terminations occurring after May 8, 1996. The amended regulation would not apply in this case. The changes may cause a result different than the one dictated by the regulations in existence for the 1984 taxable year, the year in which a sale of a 50- percent interest in Bowlen I occurred.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011