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311(d) as if it had instead sold the entire interest to a single purchaser. The taxpayer had argued that the fair market value of the distributed property for purposes of determining Internal Revenue Code Sec. 311 gain must be equal to the sum of the distributed partnership interests, which were publicly traded on the date of distribution.
The facts surrounding the case are as followed. The commissioner proposed an $18.7 million deficiency determination against Pope & Talbot for the 1985 and 1986 taxable years, alleging that Pope &Talbot had incorrectly calculated the corporation's gain under IRC Sec...
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