This PodCast considers an IRS memorandum that argues against the position taken by a taxpayer arguing that his transaction literally complies with Code Sections 731 and 732.
The IRS argued that the transaction, which involved the partnership acquiring a residence for the partner to redeem his interest, actually represented the equivalent of a distribution of cash followed by the purchase of the house--a transaction that would have triggered a significant taxable gain.
The materials for this podcast can be downloaded from http://edzollars.com/2007-01-20_Literally_Too_Good.pdf .
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