ContractPartnership Agreement • May 10th, 2012
Contract Type FiledMay 10th, 2012the partners had instead agreed that B would continue as a partner with no changes to the partnership agreement or to B’s economic in- terest in partnership operations, the dis- tribution of Property A to B on January 5, 2000, would not have been inconsistent with the purpose of section 704(c)(1)(B) and this section. In that situation, Property A would not have been distributed until after the ex- piration of the five-year period specified in section 704(c)(1)(B) and this section. Defer- ring the distribution of Property A until the end of the five-year period for a principal purpose of avoiding the recognition of gain under section 704(c)(1)(B) and this section is not inconsistent with the purpose of section 704(c)(1)(B). Therefore, A would not have rec- ognized gain on the distribution of Property A in that case.