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If not, Form 8615 is not required and the child's income is taxed at his or her own tax rate.

Some parents can choose to include the child's interest and dividends on the parent's return if certain requirements are met.

Each partner has a tax basis in the partnership, determined by the amount of after-tax value he’s contributed to the partnership.

When the partnership liquidates, the partner can recover his entire basis tax-free.

constituting more than 50% of the value of X Co.'s outstanding stock ( 267(b)(2)).

While Whiteacre was not distributed pro rata among X Co.'s shareholders, it was not distributed to a related person (within the meaning of 267).

liquidating distribution capital gain-41

Basis in a partnership is a moving target, requiring frequent adjustments.

purchased a Whiteacre (unimproved land) in 1990 at a cost of ,000. was liquidated and distributed its assets among its three shareholders. Since C owned only 20% of X Co.'s outstanding stock, C is not a related person to X Co. To be a related person, C would have had to have actual and constructive ownership of stock of X Co.

As noted in , Whiteacre is not disqualified property.

Liquidating a partnership results in a gain or loss depending on how each partner’s distribution compares to his basis.

If the distribution exceeds his basis, he recognizes a gain.