IRS Urged to Treat Some Contingent Liabilities as Property

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Contingent liabilities should qualify as “property” in determining basis adjustments to partnership property under tax code Section 743(b) and in allocating those adjustments under Section 755, the New York State Bar Association Tax Section says. In a letter to IRS and the Treasury Department, the section addresses whether and under what circumstances a partnership should be required to allocate basis adjustments to those liabilities. The section urges IRS and Treasury to issue guidance to more closely harmonize the treatment of contingent liabilities in taxable asset acquisitions with the treatment of such liabilities in taxable transfers of partnership interests.

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