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IRS Issues Guidance on Transfer of Partnership Property in Satisfaction of Guaranteed Payment

The IRS yesterday issued Rev. Rul. 2007-40, 2007-25 I.R.B. ___ (6/18/07), which provides that a transfer of partnership property to a partner in satisfaction of a guaranteed payment under § 707(c) is a sale or exchange under § 1001, not a distribution under § 731.


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