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Assumption of Partnership Debt
In previous articles liability relief from a partnership has been discussed.  Generally, liability relief from a partnership is deemed a distribution to the partner who has been relieved of the liability.  But, what happens when a partner is relieved of liability at the liquidation of the partnership?  Can liability relief be deemed a liquidating distribution...
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Under Internal Revenue Code section 752(a) an increase in a partner’s share of partnership liabilities, or an increase in a partner’s individual liabilities by reason of the assumption by such partner of a partnership liability or liabilities, shall be considered as a contribution of money by such partner to the partnership.  Because the assumption of...
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