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What are the relevant facts per IRC 704(b) property distributions to partners, for tax purposes?

The most relevant facts are: Is there substantial economic effect? Is there economic effect? Is that effect substantial? Do the facts and circumstances support, that the taxpayer participated in the activity on a “regular, continuous, and substantial basis” during the taxable year?

Additional resources provided by the author

1. Internal Revenue Code

2. U.S. Constitution – 16th Amendment

3. Practical Guide to Partnerships & LLCs 9th Edition, By Robert Ricketts & Lanny Tunnell

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