Howard E. Abrams (Emory) has published Partnership Book-Ups, 127 Tax Notes 435 (Apr. 26, 2010). Here is the abstract:

In Rev. Proc. 2009-70, the IRS asked for guidance regarding the proper allocation of partnership built-in gain. This article offers two sets of three recommendations. The first set proposes technical modifications to the computation of allowable book-ups to ensure that the values ascribed to partnership assets correspond with objectively verifiable values. The second set of recommendations proposes more radical changes to the allocation of built-in gain when book-ups are triggered by distributions of partnership property to ensure that tax allocations properly correspond to economic sharing of gains and losses.

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