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Before calling a distribution tax-free

Study note · Sergey Syso · Updated November 15, 2026

Identify cash, deemed cash, outside basis and the special rules before reaching a conclusion.

For a simple cash distribution, § 731 generally recognizes gain when money exceeds outside basis immediately before the distribution. A reduction in the partner’s share of liabilities may be treated as money distributed under § 752(b). Certain marketable securities can also count as money.

Property distributions require additional basis rules. Disproportionate distributions involving hot assets, contributed property and other special situations need their own analysis. A current distribution is not a general opportunity to recognize a loss.

Work through an example

Simplified illustration: $18,000 cash distributed against $15,000 outside basis produces $3,000 gain and leaves no outside basis, assuming no liabilities, other property or special rules. Change the facts and the calculation may change.

Return to the sources

First edition: November 15, 2026. Educational scope and current links reviewed for this release. Source text and effective dates control.

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