- 19 - Countryside interest as of January 1, 2000, (2) the changes in both his share of those liabilities and that basis between January 1 and the December 26, 2000, liquidating distribution, and (3) the effect of the liquidating distribution on his share of those liabilities. Participating partner represents that Mr. Winn’s adjusted basis in his interest in Countryside immediately before the liquidating distribution to him was $19,937,590, and the amount of money considered distributed to him pursuant to section 752(b) in connection with the liquidating distribution (i.e., the net decrease in Mr. Winn’s share of Countryside’s and MP’s liabilities resulting from the liquidating distribution) was $19,656,762.11 Because the net decrease in Mr. Winn’s share of those liabilities resulting from the liquidating distribution ($19,656,762) was less than his adjusted basis for his interest in Countryside immediately before that distribution ($19,937,590), Mr. Winn argues that, pursuant to section 731(a)(1) (which limits the gain recognized to a partner on any distribution from a partnership to the amount of money distributed in excess of the partner’s adjusted basis in the partnership at the time of the distribution), he realized no gain on the liquidating distribution. 11 The exhibit states that the liquidating distribution relieved Mr. Winn of $22,142,736 of Countryside’s liabilities in existence as of Dec. 26, 2000, but that Mr. Winn’s retained liability representing his share of CLPP’s share of MP’s $3.4 million (plus interest) liability to CB&T was $2,485,974, resulting in net relief from liabilities for Mr. Winn of $19,656,762.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: March 27, 2008