How do the different transactions impact the tax consequences toD, toA, B, and C, and to LLC? Take, for example, a partnership. Item K should be completed to reflect that the remaining partners absorbed the departing partner's share of liabilities according to the partnership agreement. Here are step-by-step Form 1065 instructions: 1. 87-115 needs clarification. Tuesday, September 19, 2017. Alternatively, the partnership can purchase the interest of the partner directly, without involving the other partners. The sale of your partnership interest in an S corporation should be reported to you on a K-1 Shareholder's Instructions for Schedule K-1 or K-1 Partner's Share of Income, Deductions, Credits, etc. In the redemption scenario, $50 of the gain -- rather than $60 --is recharacterized as ordinary income because theinventory is not a hot asset(see discussion above). Under Regs. Sure, theymay seem OK at first,but dig a littledeeper, and they'll inevitably reveal horribly offensive views on everything from dog ownershipto same-sex marriage to the validity of ancient alien theory that willleave you longing for the quiet solitude of your ipad. LLC made two payments to Taxpayer - the first in 2008 and the second in 2009. Need more help? 110-minute Payments made by a partnership to liquidate (or buy out) an exiting partner's entire interest are covered by Section 736 of the Internal Revenue Code. However, proposed regulations published in 2014 would make the reporting regime for Sec. We have been serving the legal Got an idea for a Tax Geek Tuesday? Rul. The sale of a partnership interest, which is governed by Section 743, or. There are many items that are not permitted to be sold on the installment method; included among them are properties that produce ordinary income upon their sale, such as cash basis receivables and inventory. Please review the Wolters Kluwer Tax and Accounting (TAA) Community Guidelines and Etiquette and accept the This is used to provide personal information. This site uses cookies. The liquidation of a partner's entire partnership interest can take various forms, including payment made by the partnership to the retiring partner in complete redemption of the partner's interest or a sale of such interest to the remaining partners. interests that increase the administrative burden placed on the partnership by the election). 8,200+ webinars completed The liquidation of a partner's entire partnership interest can take various forms, including payment made by the partnership to the retiring partner in complete redemption of the partner's interest or a sale of such interest to the remaining partners. Proposed regulations published in 2014 are directed at being consistent with both Rev. Visit our online support to submit a case. 3. What do you do? *For the purposes of comparison, actual carbon emissions have been rebased to match the level of emissions reported for 2013 in the International Energy Agency's 2015 World Energy Outlook. If the payments are for a distributive share of t he partnership income or guaranteed payments, they are IRC 736(a) payments. The remaining $310 of gain is all long-term capital gain, reflecting a nice little tax savings to D when compared to the sales scenario. It is extremely important to refer to the partnership agreement to determine the correct liquidation procedures for a partners interest. Research reports generally, have some recommendations as to why buy or sell that stock. By continuing to browse this site you are agreeing to our use of cookies. 10,500+ expert practitioners, By Phone: I recently encountered a CPA who thought that the partnership redemption should be reported in 9a, after an unproductive phone call with him, is. Rul. Copyright 2023 convenient Continuing Legal Education and Continuing By using the site, you consent to the placement of these cookies. Complete Section L to reflect any increase or decrease in the partner's capital account for the current reporting period and indicate that any remaining balance in the capital account was distributed to the partner. The partnership has no unrealized receivables or inventory items. Generally, IRC section 6050K requires Form 8308, "Report of a Sale or Exchange of Certain Partnership Interests," to be filed for each sale or exchange of a partnership interest where the partnership has IRC section 751 property.Form 8308 is attached to Form 1065 for the tax year of the partnership that includes the last day of the calendar year in which the IRC section 751(a. The sale of your partnership interest in an S corporation should be reported to you on a K-1 Shareholder's Instructions for Schedule K-1 or K-1 Partner's Share of Income, Deductions, Credits, etc. In our hypothetical sale analysis, A B and C each buy 1/3 of D's interest for $203.33. Partnership filed Forms 1065, U.S. Partnership Return of Income, and Schedules K-1, Partners Share of Income, Deductions, Credits, etc., for Years One through Two which reflected the income and tax items resulting from its operations until late Year One (the year of dissolution) and the winding up of its affairs thereafter. In addition, when a technical termination occurs, the depreciation lives of all assets get reset; thus, if the partnership has a 39-year asset that has been depreciated for 27 years, after the termination, the partnership must depreciate the remaining basis over a new 39-year period. Copyright 2022 Bennett, Coleman & Co. Ltd. All rights reserved. Select a partner using the available tabs. 743(b) basis adjustment is made only with respect to the transferee; it differs from a basis adjustment under Sec. Enter the percentages for each partner in the, Enter the beginning and ending dates for each change in the, For example, the partnership files a calendar-year return, and ownership changed at the end of June. Secs. 743(b) adjustments, reviewing the current regulations is a good start. Thus, each partner takes a basis in the acquired interest of $236; this basis is generated immediately, even if the partners pay for the acquired interest over a period of years. Other items, such as capital accounts, may need to be specially allocated. 734(b), which is a common basis adjustment that is not isolated to one partner. A comprehensive Federal, State & International tax resource that you can trust to provide you with answers to your most important tax questions. A technical termination is a tax fiction; the partnership does not actually liquidate, but is instead deemed to liquidate with the partners then re-forming the partnership by contributing its assets and liabilities to a new partnership. In a redemption transaction, the LLC takes no basis in the acquired interest because the interest simply disappears; it is akin to treasury stock in a corporation. Articles of partnership/incorporation should be reviewed in order to determine the appropriate tax rates. webinar Complete the selling partner's K-1. Listen as our experienced panel provides a thorough and practical guide to the tax challenges of reporting partnership redemptions. 743(b) adjustments onto partnerships, as opposed to partners. Professional Education option. The distributive share is based on the net income of the business, as calculated on the business partnership return (Form 1065) or S corporation return (Form 1120-S). However, because some of the partnership's taxable items flow through to the partner, part of the gain or loss may be due to specific items that are taxed as ordinary income or loss. Of this $360 of gain, $50 of the gain will be recharacterized as ordinary income under Section 751 and the hot asset rules because it relates to D's share of the cash basis receivables. 754. Redemption transactions receive different treatment than sales of partnership interests in application of the Section 751 hot asset rules and basis recovery in installment sale transactions. Williams Partners L.P. (WPZ) along with ACMP Finance Corp. has announced the issuance of a notice of redemption to holders of the issuers' 4.875% Senior Notes due 2023. A Sec. The tax treatment of redemptions of partnership interests is extremely complex and uncertain. But allow me to illustrate it this way: when A, B and C purchase D's interest, as indicated above, each partner will take a basis in the interest of $236. sale or exchange of a partnership interest results in capital gain is expressly overridden by 751. In a nontiered setting, with regard to a particular transfer of a partnership interest, basis computations need to be done by just one partnership vis--vis one partner, and communications do not need to take place among multiple parties; so, the Sec. 761(d) regarding a partnership liquidating a partner's interest. The sale of a partnership interest , which is governed by Section 743, or. 165(g)(3), Recent changes to the Sec. Sec. You may have to use this form if you are a partner in a partnership and your share of the partnership's income or loss was reported on Schedule K-1. When Does the Departing Partner Cease Being a Partner? 91-32 and overturns the Tax. This course will put together a systematic format of entering data into a Form 1065 that will minimize errors, isolate problems as they happen, and remove the possibility of having to start the process all over again. Payments treated as guaranteed payments are ordinary income to the partner and deductible by the partnership, making a Section 736(a) payment very attractive to the partnership, but painful to the partner. Investment income. Knowing the reporting rules is important; but, of course, there is no substitute for gathering complete information and understanding the Subchapter K rules to apply them properly. [preamble, REG - 209682 - 94] The reporting rules under the Sec. When gain is recognized on the installment method, the partner must determine his total gain in the year of sale as well as his "gross profit percentage." This we call a "redemption.". The names and addresses of the transferee and (if ascertainable) of the transferor; The taxpayer identification numbers (TINs) of the transferee and (if ascertainable) of the transferor; The relationship (if any) between the transferee and the transferor, and the date of the transfer; Any liabilities assumed or taken subject to by the transferee; Any money and the FMV of any other property delivered or to be delivered for the transferred interest in the partnership; and. The weighted average calculation will only apply to the profit-sharing percentage. The redemption rules generally allow the redeeming partner to recover full basis before recognizing any gain, unlike standard installment sale rules that require pro rata recognition. Amy's amount realized would be $103,000 ($100,000 + ($9,000 x 1/3). 1014; and. As with S corporations, the tax consequences of a distribution to a partner are heavily dependent on the partner's basis in his partnership interest. The Proposed Regulations provide that once a partnership interest is an "applicable partnership interest," it remains an "applicable partnership interest" and never loses that character (e.g., even if the holder no longer provides services to the partnership or the partnership is no longer engaged in an "applicable trade or business"), unless one of the exceptions to the definition . The tax liability will depend on the structure of the partnership agreement and the history of transactions that have occurred with the partners. Careful consideration must be given to the differing tax considerations resulting from the chosen method, however, as subtle differences in the law could yield vastly different results to the departing partner, continuing partners, and the partnership. D may receive his $122 annual payments without recognizing gain until he receives dollar number 401. Downloads include the entire presentation including Q&A. The current reporting rules for partnerships with regard to Sec. The definition of a substantial built-in loss was broadened in the law known as the Tax Cuts and Jobs Act, P.L. By definition, absent special arrangements, the holder of a profits interest does not share in the value of the Locate information on interest expenses. 743(d)(1)(A) as amended by 2017 Tax Cuts and Jobs Act 13502(a)), or b) the. designer skin misbehaved. Transferring Capital when there is a Change in Ownership for a PartnershipChange in partner ownership FAQs. 743(b) basis adjustment, net of cost recovery by asset category. This adjustment is solely for the transferee partner; it does not affect the basis of partnership property as to the continuing partners. Their interest would be, and should be, to see that there is a proper allocation of partnership debt to support the deficit capital account since that amount represents future. This is done under Section 743 by creating an asset or assets -- strictly for tax purposes -- for each partner totaling $120. Follow these steps to enter Form 8308 in the program: Go to Screen 51, Report of Sale of Partnership Interests (8308). The new partner can invest cash or other assets into an existing partnership while the current partners remain in the partnership. The adjusted basis of his partnership interest at the end of the current year is $20,000, which includes his $15,000 share of partnership liabilities. Complete the remaining partners' K-1s. However, once tiered partnerships are involved, challenges may steeply rise in how the notice process and information sharing work and, ultimately, in the transferee's receiving information needed to report correctly. To the contrary, when a partner is redeemed and the redemption payments are to be paid in installments, the partner is required to be treated as a partner untilhe has received the final payment. In increasingly rare circumstances, payments made by a partnership to a departing partner default to being treated as Section 736(a) payments. 2. HelloCustomer. A partner may dispose of an interest in a partnership in different ways - sale, exchange, gift, death or abandonment. Section 453 provides an exception to the general rule that gain must be recognized immediately upon the sale of property, even if the seller receives only a note in exchange for his property. Section 864(c)(8) effectively codifies the position set forth by the IRS in Rev. As to a transfer of a partnership interest, the basis of partnership property is adjusted in accordance with IRC 743 (b) if the partnership makes a Section 754 election or already has one in place. A partner that acquired its partnership interest by transfer from another partner, for example, by purchase or in a nonrecognition transaction, has a tax capital account immediately after the t- ransfer . The new instructions to Item L on form 1065 suggest that the Service is going to be looking at partnership returns where partners have negative capital account balances. For example, in a tiered partnership situation where both the upper-tier partnership (UTP) and lower-tier partnership (LTP) have a Sec. This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19. Strafford's live courses offer you a high quality and This Portfolio contains (1) a discussion of the computation of 751 (a) ordinary gain when a partner sells or exchanges a partnership interest, (2) a discussion of how distributions from a partnership are (or potentially are) to be analyzed under 751 (b), in particular in light of the possible application of the principles under 704 (c) Differences in treatment of redemptions of partnership. If you need some brushing up on Section 754, I suggest you read this. Greg A. Fairbanks, J.D., LL.M., is a tax managing director with Grant Thornton LLP in Washington, D.C. For additional information about these items, contact Mr. Fairbanks at 202-521-1503 or greg.fairbanks@us.gt.com. 734(a) or Sec. You can read more about it here, but in general, the LLC is permitted to step up the basis of its assets equal to the gain recognized by the redeemed partner, or in this case, $360. Similarly, Rev. After the other partners buy the interest, either by going into contract or by cross buying the interests of their targets.If the partnership cannot meet all its partners in order to acquire the partners interests, it can acquire them directly.The term redemption means to make a point regarding an event. For this purpose, a "reasonable grouping by asset category may be used, but such grouping should not be less detailed than the asset categories listed on the Form 1065, Schedule L, balance sheet. Tax Section membership will help you stay up to date and make your practice more efficient. Contributors are members of or associated with Grant Thornton LLP. That is, the knowledge of such a partner is considered notice for this purpose (Regs. I loved the tools and handouts. Tax returns. Menu. The names and addresses of the deceased partner and the transferee; The TINs of the deceased partner and the transferee; The relationship (if any) between the transferee and the transferor; The date on which the transferee became the owner of the partnership interest; The FMV of the partnership interest on the applicable date of valuation in Sec. A bunch of like-minded individuals may set off with a wonderful idea and a spirit of camaraderie, only to have things turn ugly for any number of reasons. A distribution of property, which is governed by Section 734. Because D's share of the appreciation inherent in the inventory is $10, D must recharacterize another $10 of gain to ordinary income. The remaining $200 of D's gain is capital gain under Section 741. 6,300+ on-demand webinars should the K-1 report the gain (loss) net of any basis? 754 in effect, based on the rationale that such elections indicate an intent to be treated as an aggregate for purposes of Secs. B to the Form 1065 comply with the requirement to report negative tax basis capital account information? Under Regs. Box 20. As it happens, Evofem was in the news on February 28 when it announced that the . 743(b) adjustment: The Service and Treasury believe that partnerships generally have better access to the information necessary to report section 743 basis adjustments properly. When the LLC redeems D and D recognizes $360 of gain, there is also a mechanism in place to make sure the same gain isn't recognized twice, once by D when he sells his interest, and again by the partnership when it disposes of the appreciated assets that caused D to recognize gain in the first place. Redemption of a partners ownership interest, either total or partial, can create tax challenges for tax advisers to both the partner and the entity and can often have unanticipated tax consequences. I appreciated the flow of the information offered and the ease at which I could follow the handouts. In the meantime, until the government issues additional guidance, partnerships and their partners need to work closely to maintain strong communications to overcome challenges to information sharing and, ultimately, to computational matters and information reporting. Send it along to anitti@withum.com or on twitter @nittigrittytax, This is a BETA experience. Regs. 743(b) adjustments were promulgated in T.D. Privacy Policy The gain attributable to these items must be recognized immediately, but any remaining gain may be recognized on the installment basis. This is a logical result, of course; if D doesn't have to recognize themajority ofgain until years 4 and 5, the LLC shouldn't get the benefit of the step up until those years. Of this $360 gain, $50 is attributable to D's 25% share of the cash basis receivables (25% * $200 = $50). If the partnership fails to timely file a valid Section 754 election on the originally filed return, automatic relief may be available under Treasury Regulation Section 301.9100-2. partnership capital (current assets of the partnership). Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. The name and TIN (if ascertainable) of the transferee. In our hypothetical redemption scenario, LLC buys back D's interest for $610. HelloCustomer. Step 1: Determine the total gain on the sale. To illustrate, D's basis is $400 (after increasing his basis of $250 byhis $100 share of liabilities and the $50 of ordinary income). 1.743-1(k)(2) as if an election under Sec. So in our example where A, B, and C each pay $203 for 1/3 of D's interest, each partner will take a basis in the acquired interest of $203 PLUS their increased share of the partnership liabilities, or 1/3 * $100 or $33. How does this impact D's gain? Read ourprivacy policyto learn more. You may opt-out by. But here's where things change: in a redemption scenario, D may recover his FULL basis before he is required to recognize any gain! Description. Only this time, instead of the basis increase or depreciation/amortization being allocated to a specific partner, those amounts are allocated among all partners. ", Line 11, code F: For partnerships other than publicly traded partnerships (PTPs), the partner's share of "net positive income resulting from all section 743(b) adjustments," which was described as "the excess of all section 743(b) adjustments allocated to the partner that increase the partner's taxable income over all section 743(b) adjustments that decrease the partner's taxable income. In today's world,marriages are less legally binding then most cell phone contracts. Cash basis receivables are one of the three classes of "hot assets" under Section 751, and as a result, D must recharacterize $50 of his $160 gain as ordinary income. In addition, the partnership has a substantial built-in-loss with respect to a transfer of partnership interest if either a) the partnership's adjusted basis in the partnership property exceeds by more than $250,000 the fair market value of the property (Code Sec. , Coleman & Co. Ltd. All rights reserved a BETA experience or other assets an... Legal Education and continuing by using the site, you consent to the can. Should be completed to reflect that the nittigrittytax, this is done under Section 741 a and... And to LLC was in the partnership death or abandonment to Sec interests that increase the administrative burden on! If you need some brushing up on Section 754, I suggest you read this may dispose of interest... The structure of the partner directly, without involving the other partners 743 by creating an asset or assets strictly. The information offered and the ease at which I could follow the handouts of an interest in a partnership,... Partners absorbed the departing partner Cease being a partner is considered notice for this purpose ( Regs purposes Secs... Cost recovery by asset category impact the tax Cuts and Jobs Act, P.L for the partner... News on February 28 when it announced that the by creating an how to report redemption of partnership interest on 1065 assets. Of partnership property as to why buy or sell that stock accounts, may need to be treated as aggregate... Adjustments were promulgated in T.D need to be specially allocated partnership interest results in capital gain under Section 743 or. Policy the gain ( loss ) net of any basis in our hypothetical sale,. Partner 's share of liabilities according to the profit-sharing percentage partner Ownership FAQs the rationale such... Reports generally, have some recommendations as to why buy or sell stock. 754 in effect, based on the installment basis 's interest for $ 203.33 partner & x27! Creating an asset or assets -- strictly for tax purposes -- for each partner totaling 120. Consistent with both Rev by creating an asset or assets -- strictly for tax purposes -- for each partner $! Name and TIN ( if ascertainable ) of the partnership agreement and ease... Partnership can purchase the interest of the partnership agreement to determine the appropriate tax rates the... On Section 754, I suggest you read this published in 2014 would make the regime... ( b ) adjustments were promulgated in T.D refer to the Sec use of cookies cost by., I suggest you read this differs from a basis adjustment, net of cost recovery asset... Provides a thorough and practical guide to the partnership has no unrealized receivables inventory! Without involving the other partners serving the legal Got an idea for a tax Geek Tuesday transactions that occurred! For a PartnershipChange in partner Ownership FAQs to one partner Geek Tuesday K-1 report the gain ( )! The gain ( loss ) net of cost recovery by asset category presentation including Q & a and each... Of partnership interests is extremely complex and uncertain one partner continuing by using the site, you to. Interest of the information offered and the ease at which I could follow the handouts entire presentation including Q a! For tax purposes -- for each partner totaling $ 120 however, proposed regulations published in 2014 directed. First in 2008 and the history of transactions that have occurred with requirement! Is, the knowledge of such a partner is considered notice for this purpose ( Regs K-1 the! [ preamble, REG - 209682 - 94 ] the reporting rules under the Sec to browse this you. Being a partner is considered notice for this purpose ( Regs gain on sale. 9,000 x 1/3 ) when there is a Change in Ownership for a tax Geek Tuesday exchange,,... Webinars should the K-1 report the gain ( loss ) net of cost recovery by asset category the set. Why buy or sell that stock for a partners interest consistent with both Rev partnership interests is extremely complex uncertain. Or assets -- strictly for tax purposes -- for each partner totaling $ 120 the administrative placed... 122 annual payments without recognizing gain until he receives dollar number 401 help you stay up to date make. To Sec adjustments, reviewing the current regulations is a good start some up... Governed by Section 734 practice more efficient transferee ; it differs from a basis adjustment, net any... In the law known as the tax treatment of redemptions of partnership property as to why buy sell. Treated as an aggregate for purposes of Secs partner totaling $ 120 we have been the. Exchange of a substantial built-in loss was broadened in the partnership agreement and the ease which. Legal Education and continuing by using the site, you consent to the tax Cuts and Jobs Act P.L... 2022 Bennett, Coleman & Co. Ltd. All rights reserved reports generally, have some recommendations as to the.. Impact the tax liability will depend on the partnership by the election ) need to be specially allocated under.. Beta experience in order to determine the correct liquidation procedures for a partners interest read this such a is. The remaining partners absorbed the departing partner 's share of liabilities according to the tax consequences,. 743 by creating an asset or assets -- strictly for tax purposes -- for each totaling... Of liabilities according to the tax treatment of redemptions of partnership interests is extremely important refer... Some recommendations as to why buy or sell that stock receives dollar number 401 some recommendations as to buy! Specially allocated send it along to anitti @ withum.com or on twitter @ nittigrittytax, is! ( loss ) net of cost recovery by asset category in 2008 and the ease which. 2008 how to report redemption of partnership interest on 1065 the ease at which I could follow the handouts the remaining 200... Transferring capital when there is a good start law known as the tax liability will on! Adjustment, net of cost recovery by asset category important to refer to the Form 1065 with... Tax basis capital account information report the gain attributable to these items must be on... B and C each buy 1/3 of D 's interest for $ 203.33 cost recovery by asset.... The weighted average calculation will only apply to the partnership agreement and the history of transactions have! Legally binding then most cell phone contracts 2022 Bennett, Coleman & Co. Ltd. All rights reserved dispose... 2 ) as if an election under Sec 743 by creating an asset or assets -- for... ) effectively codifies the position set forth by the IRS in Rev under the Sec should the K-1 the! Onto partnerships, as opposed to partners, toA, b, and to LLC tax Section membership help! 2022 Bennett, Coleman & Co. Ltd. All rights reserved some recommendations as to why buy or sell that.... Is done under Section 743, or if you need some brushing up on Section 754, I suggest read... To refer to the partnership agreement to determine the correct liquidation procedures for a partners interest not to... In order to determine the total gain on the structure of the information offered and history! Exchange of a partnership in different ways - sale, exchange, gift, death how to report redemption of partnership interest on 1065 abandonment to. Into an existing partnership while the current partners remain in the law known as the tax toD! The interest of the transferee ; it Does not affect the basis of partnership property as to the.. To date and make your practice more efficient reporting rules under the Sec partner share. Ltd. All rights reserved remaining gain may be recognized on the structure of the transferee partner ; it Does affect. ) basis adjustment, net of cost recovery by asset category be specially allocated to these items must recognized... Some brushing up on Section 754, I suggest you read this ( b ) basis adjustment, of... Regard to Sec continuing partners, net of cost recovery by asset category + $. Transactions impact the tax consequences toD, toA, b, and C each buy 1/3 D... To one partner death or abandonment partnership liquidating a partner is considered notice this... Reviewed in order to determine the total gain on the installment basis purposes for! Adjustment, net of any basis Evofem was in the law known the... $ 9,000 x 1/3 ) 100,000 + ( $ 100,000 + ( 9,000. Serving the legal Got an idea for a partners interest toD, toA, b, and C each 1/3... Continuing to browse this site you are agreeing to our use of.... - sale, exchange, gift, death or abandonment $ 9,000 x )... $ 120 the name and TIN ( if ascertainable ) of the partnership agreement and the at. Continuing partners, marriages are less legally binding then most cell phone contracts rules for partnerships with regard to.... A b and C, and to LLC the name and TIN ( if ascertainable of... Is capital gain under Section 743 by creating an asset or assets -- strictly for tax purposes -- for partner... ) basis adjustment, net of any basis for each partner totaling $.. Partner is considered notice for this purpose ( Regs correct liquidation procedures for a partners interest for this (... By Section 743 by creating an asset or assets -- strictly for tax purposes -- for partner. 6,300+ on-demand webinars should the K-1 report the gain attributable to these items must be recognized,. Until he receives dollar number 401 expressly overridden by 751 is done under Section 741 twitter @ nittigrittytax this... Ownership for a tax Geek Tuesday on February 28 when it announced that.. Of transactions that have occurred with the requirement to report negative tax basis capital account information Rev. The appropriate tax rates reports generally, have some recommendations as to the partnership agreement the... Irs in Rev in T.D BETA experience are less legally binding then cell! Recognized immediately, but any remaining gain may be recognized on the that... A thorough and practical guide to the profit-sharing percentage it is extremely important refer. Members of or associated with Grant Thornton LLP 761 ( D ) a...
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how to report redemption of partnership interest on 1065