Sale of Partnership Interest, including but not limited to:
- Allocating purchase price to the Code Section 1060 asset categories;
- Shoving as much as possible in the allocation into capital gain assets for sellers and to ordinary income for purchasers;
- Installment sales of partnership assets;
- 754 elections with 743 and 734 book up / down of inside basis and allocation under 755;
- Book up of 704(b) capital accounts and tracking thereafter to prevent equity shifts;
- Closing a partnership taxable year, and technical termination under 708(b);
- Contingent consideration in the sale of partnership interest;
- Transfers of assets to and from partnerships and analyzing and structuring around the disguised sale rules; and
- Allocating income in the year of change.
