id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-504	Tierney, James E.	Reassessing Sales and Liquidations of Partnership Interests after the Omnibus Budget Reconciliation Act of 1993	2022	48	.pdf	application/pdf	23053	962	53	As under prior law, section 736(b)(1) treats payments for a partner's share of partnership property as a distribution to the retiring partner, while section 736(b)(2) excludes from this treatment payments for a retiring partner's share of unstated good will and unrealized receivables (now meaning only traditional unrealized receiv- ables) 89 and places them into section 736(a), where they are characterized as a distributive share of partnership income or a guaranteed payment. A partner's proportionate share of the partnership's basis in its property is the sum of his interest as a partner in partnership capital and surplus, plus his share of partnership liabilities.	cache/ftr-504.pdf	txt/ftr-504.txt