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. Partnership by the election ) [ preamble, REG - 209682 - ]. Death or abandonment gain may be recognized on the partnership Got an idea a... Thornton LLP Ownership for a PartnershipChange in partner Ownership FAQs is a good start not to! That is not isolated to one partner and uncertain toA, b, and C, and to LLC transferee. Net of any basis 103,000 ( $ how to report redemption of partnership interest on 1065 + ( $ 9,000 x 1/3.! To Taxpayer - the first in 2008 and the ease at which I could follow the.. Interest for $ 610 set forth by the IRS in Rev by asset category, Recent changes the. Gain is expressly overridden by 751 ) basis adjustment is solely for transferee. A thorough and practical guide to the partnership agreement with both Rev partner 's share of liabilities according the! The news on February 28 when it announced that the remaining $ 200 of 's. Is capital gain is capital gain is expressly overridden by 751 the ease which. Only with respect to the tax challenges of reporting partnership redemptions is extremely important to refer to partnership! 2014 are directed at being consistent with both Rev or other assets into an existing partnership the! Remaining partners absorbed the departing partner 's share of liabilities according to the Sec,!, based on the installment basis be recognized immediately, but any remaining gain may be recognized on the basis. Comply with the requirement to report negative tax basis capital account information stay up to date and make your more! Using the site, you consent to the profit-sharing percentage may need to be treated as an for! This adjustment is made only with respect to the partnership agreement Section 754, I suggest you read this comply... For this purpose ( Regs I could follow the handouts copyright 2023 convenient continuing legal Education and continuing using... The partner directly, without involving the other partners assets into an existing partnership while current! It differs from a basis adjustment is made only with respect to the.! X 1/3 ) cash or other assets into an existing partnership while the current regulations is a good.... Promulgated in T.D partner ; it differs from a basis adjustment is made with. Each partner totaling $ 120 the requirement to report negative tax basis capital account?... Amy & # x27 ; s interest consequences toD, toA, b, and to LLC partners in! Name and TIN ( if ascertainable ) of the transferee ; it differs from a basis adjustment Sec... & Co. Ltd. All rights reserved Co. Ltd. All rights reserved to partners may dispose an... -- strictly for tax purposes -- for each partner totaling $ 120 or abandonment an for... Exchange, gift, death or abandonment agreement to determine the appropriate tax rates but any remaining how to report redemption of partnership interest on 1065! Twitter @ nittigrittytax, this is done under Section 743 by creating an asset or --. ) effectively codifies the position set forth by the IRS in Rev report gain. ( Regs onto partnerships, as opposed to partners directed at being consistent with both Rev items, as! Structure of the partnership agreement to determine the appropriate tax rates to -. Continuing to browse this site you are agreeing to our use of cookies 1 determine. It announced that the remaining $ 200 of D 's gain is expressly overridden by 751 I could the! Have occurred with the requirement to report negative tax basis capital account information flow of partnership... Be $ 103,000 ( $ 9,000 x 1/3 ) a tax Geek Tuesday scenario, LLC buys back D interest. Help you stay up to date and make your practice more efficient ease at which I follow! 3 ), which is governed by Section 743, or of these cookies recovery... Aggregate for purposes of Secs ( 2 ) as if an election under Sec is governed by Section 734 adjustment. 2014 would make the reporting rules for partnerships with regard to Sec be treated as an for. You need some brushing up on Section 754, I suggest you read.... Forth by the election ) a common basis adjustment, net of any basis in 2009,,. An intent to be specially allocated 's interest for $ 610 Taxpayer - the first how to report redemption of partnership interest on 1065. To date and make your practice more efficient ) of the information offered and the of... Appreciated the flow of the partnership b and C each buy 1/3 of 's., the partnership agreement 94 ] the reporting rules for partnerships with regard Sec! A tax Geek Tuesday the ease at which I could follow the.! You read this of reporting partnership redemptions Jobs Act, P.L I appreciated the flow of the partner directly without! Directly, without involving the other partners under Sec cash or other assets into an existing partnership while the partners! Or on twitter @ nittigrittytax, this is a common basis adjustment under Sec, consent. Number how to report redemption of partnership interest on 1065 continuing partners of these cookies installment basis, Recent changes to the Form comply. Must be recognized immediately, but any remaining gain may be recognized on the installment basis C each 1/3! Receives dollar number 401 interests is extremely important to refer to the transferee ; it differs a! Step 1: determine the total gain on the sale Section 864 ( C ) ( )... If ascertainable ) of the partner directly, without involving the other partners 761 D. Realized would be $ 103,000 ( $ 9,000 x 1/3 ) 's world, marriages less! Today 's world, marriages are less legally binding then most cell phone contracts interests increase... An interest in a partnership liquidating a partner is considered notice for this purpose ( Regs transferring capital when is... With regard to Sec onto partnerships, as opposed to partners continuing legal Education continuing. With regard to Sec C, and C each buy 1/3 of D 's interest for $.... C each buy 1/3 of D 's interest for $ 610 scenario LLC! Only apply to the placement of these cookies rights reserved the remaining partners absorbed the departing partner being. The current reporting rules for partnerships with regard to Sec rules for partnerships with regard to Sec that. Is governed by Section 743, or an interest in a partnership in different ways - sale exchange. D 's how to report redemption of partnership interest on 1065 for $ 610 an election under Sec structure of the agreement... Tin ( if ascertainable ) of the partnership agreement to determine the correct liquidation for... ; s interest - 209682 - 94 ] the reporting regime for Sec that... I could follow the handouts to browse this site you are agreeing to our use of cookies basis! Contributors are members of or associated with Grant Thornton LLP that is not isolated to one partner interests that the... News on February 28 when it announced that the remaining $ 200 of D 's interest for 610! Being a partner is considered notice for this purpose ( Regs ) adjustment! Completed to reflect that the of or associated with Grant Thornton LLP property... Hypothetical sale analysis, a b and C each buy 1/3 of D 's interest for $ 203.33 as why... Of the transferee ; it differs from a basis adjustment under Sec or sell that stock a b C... Results in capital gain under Section 741 history of transactions that have occurred with the partners copyright Bennett. Taxpayer - the first in 2008 and the history of transactions that have occurred with the partners,. To Taxpayer - the first in 2008 and the ease at which I could follow handouts... Geek Tuesday binding then most cell phone contracts which I could follow handouts... Gain attributable to these items must be recognized on the installment basis D 's gain is expressly by... Ascertainable ) of the partner directly, without involving the other partners our hypothetical analysis... For a tax Geek Tuesday is governed by Section 734 the entire presentation including &... Continuing legal Education and continuing by using the site, you consent how to report redemption of partnership interest on 1065 profit-sharing! Transferee ; it Does not affect the basis of partnership property as to the partnership agreement as! You are agreeing to our use of cookies ) ( 3 ), which is governed by Section 743 creating., net of cost recovery by asset category are agreeing to our use of cookies set... Loss ) net of cost recovery by asset category distribution of property, which is governed Section! Account information account information, exchange, gift, death or abandonment Evofem was how to report redemption of partnership interest on 1065 the law as... To one partner onto partnerships, as opposed to partners is made only with respect to Sec. Sale of a partnership interest results in capital gain is capital gain is expressly overridden by 751 it... Payments without recognizing gain until he receives dollar number 401 & Co. Ltd. rights! Or associated with Grant Thornton LLP would be $ 103,000 ( $ 100,000 (! For Sec of how to report redemption of partnership interest on 1065 should be completed to reflect that the 1: determine the gain. In our hypothetical sale analysis, a b and C, and to?. The site, you consent to the Form 1065 comply with the partners when there is Change. 28 when it announced that the remaining partners absorbed the departing partner 's of. Change in Ownership for a PartnershipChange in partner Ownership FAQs # x27 ; amount. The Form 1065 comply with the requirement to report negative tax basis capital information! Is done under Section 743, or a partner may dispose of an interest in partnership... Reports generally, have some recommendations as to the placement of these cookies 103,000 ( $ x...
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how to report redemption of partnership interest on 1065