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QUESTION

If NonSection 751 Property is deemed sold the gain is capital.

If NonSection 751 Property is deemed sold the gain is capital. A partnership has Section 751 Property with a basis of $200 and a FMV of $1,000 and Non-Section 751 Property with a basis of $660 and a FMV of $1,000. A 50% partner with an outside basis of $430 receives a liquidating distribution of the Non-Section 751 Property. Does Section 751(b) apply?

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