Do most distributions made by a partnership require a Sec. 751 calculation?
What will be an ideal response?
No. Many current distributions are made pro rate to all partners, so Sec. 751 is not involved. Even if the distribution is not pro rate, the distribution often does not create an exchange of an interest in Sec. 751 assets for an interest in other assets. This exchange happens only when (1) the partner is reducing his or her overall interest in the partnership, or (2) an explicit agreement provides that the distribution results in a partner giving up all or part of his or her interest in some asset(s) maintained by the partnership.
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