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Relating to the allocation of partnership liabilities and the tax implication of a foreclosure

Issue

What is the allocation of partnership liabilities and the tax implication of a foreclosure?

Related Tax Rule or Regulation

Internal Revenue Code Section 465

Internal Revenue Code Section 704

Internal Revenue Code Section 731

Internal Revenue Code Section 752

Internal Revenue Code Section 1001

Tax Regulation § 1.1001-2(c),

Case Study

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