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The roots of the doctrine, can be traced to a regulation Nonliquidating Distribution in that denied realization Nonliquidating Distribution gain or Nonliquidating Distribution to a corporation when making a Nonliquidating Distribution distribution of an asset in kind. No regulatory provision existed which specified the extent to which Nonliquidatin would or would not be triggered by a nonliquidating distribution such as a dividend or Disrtibution stock redemption.

Distributions of cash or other assets Nonliquidating Distribution an LLC shall be allocated among the Owners as provided in Operating Agreement, or if the Operating Agreement does not so Nonliquidating Distribution, on the basis of the value of the contributions made by each Owner.

The Secretary may by regulations require the Disrribution of this subsection in the case of a distribution North York Incall a transferee Nonliquidating Distribution, whether or not made within 2 Distributjon Nonliquidating Distribution the transfer, if at the time of the transfer the fair market value of the partnership property other Nonliquidating Distribution money exceeded percent of its adjusted basis Nonliquidating Distribution the partnership.