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          accord with section 743(b) prior to a distribution to a partner             
          who acquired his interest in the absence of a section 754                   
          election, if three conditions exist:  (1) The fair market value             
          of the partnership's property (other than money) exceeds 110                
          percent of its adjusted basis to the partnership at the time the            
          partnership interest was acquired, (2) upon liquidation of the              
          partner's interest in the partnership immediately after                     
          acquisition, an allocation of basis under section 732(c) would              
          have shifted basis to depreciable, depletable, or amortizable               
          property from property not subject to these allowances, and (3) a           
          special basis adjustment under section 743(b) would have changed            
          the basis to the transferee partner of property actually                    
          distributed.  Sec. 1.732-1(d)(4), Income Tax Regs.; see Rudd v.             
          Commissioner, 79 T.C. 225, 240-246 (1982).                                  
               The partnership did not have a section 754 election in                 
          effect for 1984.  Up to this point, the parties remain in accord.           
          Their disagreement goes to the amount of the fair market value of           
          the player contracts and whether the section 732(d) provisions              
          applied.                                                                    
               The partnership's accountant determined that the section               
          732(d) mandatory basis adjustment rules applied, and the player             
          contract bases were adjusted in accord with section 743(b) prior            
          to the deemed distribution.  The partnership used the section               
          743(b) adjusted basis, i.e., their purported fair market values,            
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