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The amount treated as money is the security's fair market value when distributed, reduced (but not below zero) by the excess (if any) of: For more information, including the definition of marketable securities, see section 731(c) of the Internal Revenue Code. A partner does not recognize loss on a partnership distribution unless all the following requirements are met. The partner is treated as having satisfied the debt for its fair market value.If the issue price (adjusted for any premium or discount) of the debt exceeds its fair market value when distributed, the partner may have to include the excess amount in income as canceled debt.A partnership distribution is not taken into account in determining the partner's distributive share of partnership income or loss.If any gain or loss from the distribution is recognized by the partner, it must be reported on his or her return for the tax year in which the distribution is received.

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For exceptions to these rules, see Distribution of partner's debt and Net precontribution gain, later.

Other than for purposes of determining the gain, the increase is treated as occurring immediately before the distribution. The partnership must adjust its basis in any property the partner contributed within 7 years (5 years for property contributed before June 9, 1997) of the distribution to reflect any gain that partner recognizes under this rule. Any part of a distribution that is property the partner previously contributed to the partnership is not taken into account in determining the amount of the excess distribution or the partner's net precontribution gain.

For this purpose, the partner's previously contributed property does not include a contributed interest in an entity to the extent its value is due to property contributed to the entity after the interest was contributed to the partnership.

When a partnership distributes the following items, the distribution may be treated as a sale or exchange of property rather than a distribution. Inventory items of the partnership are considered to have appreciated substantially in value if, at the time of the distribution, their total fair market value is more than 120% of the partnership's adjusted basis for the property.

However, if a principal purpose for acquiring inventory property is to avoid ordinary income treatment by reducing the appreciation to less than 120%, that property is excluded.

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