26 U.S. Code § 741 - Recognition and character of gain or loss on sale or exchange
In the case of a sale or exchange of an interest in a partnership, gain or loss shall be recognized to the transferor partner. Such gain or loss shall be considered as gain or loss from the sale or exchange of a capital asset, except as otherwise provided in section 751 (relating to unrealized receivables and inventory items).
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- Property Used in the Trade or Business and Involuntary Conversions Capital Gain v. Ordinary Income Treatment : 2010-01-15
- Interest on Certain Deferred Payments : 2007-06-01
- Unrealized Receivables and Inventory Items : 2007-06-01
- Qualified Stated Interest : 2007-06-01
- Contingent Payments : 2007-06-01
- Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property : 2007-06-01
LII has no control over and does not endorse any external Internet site that contains links to or references LII.