IRS requests comments on disguised-sale prop. regs.
| Jurisdiction | United States |
| Author | Kautter, David J. |
| Date | 01 January 2002 |
In Notice 2001-64, the IRS requested comments on regulations to be proposed under Sec. 707(a)(2)(B) on disguised sales of partnership interests. Specifically, the Service seeks input on the scope and substance of such guidance, including safe harbors and exceptions.
The legislative history of Sec. 707(a)(2)(B) states that Congress intended the provision to address taxpayers characterizing what were, in substance, sales of partnership property (such as partnership interests) as contributions, followed by (or preceded by) a related partnership distribution, to defer (or...
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