Please RESPONSE or EXPLAND to the following essay: Section 751 states that amount of any...
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Accounting
Please RESPONSE or EXPLAND to the following essay:
Section 751 states that amount of any money (or gain market value of any property), received by a selling partner in exchange for all or part of his interest in the partners that is attributable to:
Unrealized receivables of the partnership.
Substantially appreciated inventory items of the partnership, or ordinary income depreciation recapture under Section 1245 or 1250 is considered as an amount realized from the sale or exchange of property other than a capital asset. Meaning, that if a partner sells his partnership interest, his share of any gain attributable to cash-basis accounts receivables, appreciated inventory, or depreciation recapture (which are commonly referred to as Hot assets) results in ordinary income rather than capital gain. The reason behind this exception is because partnerships generally do not pay tax at the entity level, it is the partners who pay the tax on their respective share of the partnership income. Similarly, if a partnership generates an ordinary business loss, the loss retains its character as ordinary when allocated among the partners
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