I stand corrected. Ill shut my mouth from now on :)

-----Original Message-----
From: Rip West [mailto:rip@montrose.net]
Sent: Tuesday, April 15, 2003 9:22 AM
To: The Club Cafe
Subject: Re: club_cafe: Departure Rules


John Medio said....

<<
Generally, under IRC 708, if more than 50% of the interests in the
partnership are sold or exchanged, the partnership will experience a
technical termination. That means the partnership's tax year is deemed
to have ended on the date of the exchange, and the resulting partnership
is a "new" one for tax election and attribute purposes.
>>
A partnership withdrawal is not considered a sale or exchange, even if a
new partner contributes money and is issued units.
Rev Rul 75-423 , 1975-2 CB 260 .

All of which is to say that a partner's withdrawal will not trigger a
termination, and Ira is right again <g>.

Rip



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