The 10 000 difference gain to be recognized by a is allocated to partners b and c and any related depreciation amortization deductions are specially allocated to b and c. Subsequently this produced a 754 adjustment for the remaining partners whereby the transferred capital was treated as a distribution to the remaining partners and should produce an offsetting step up in outside basis upon a sale. The sale of a partnership interest which is governed by section 743 or a distribution of property.
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