Extract to table

The nonrecognition rule of Section 721(a) applies broadly and without limitation as to the amount of gain or loss that would otherwise be recognized, provided that three conditions are satisfied: (i) the transferee entity must be classified as a "partnership" for federal income tax purposes; (ii) the transfer must constitute a "contribution of property" to such partnership; and (iii) the transferor must receive "an interest in the partnership" in exchange for the contributed property

704-3(d) shall be used for all Section 704(c) allocations

In the event that disclosure is required by law or regulation, Ardent Capital shall, to the extent practicable, provide us with reasonable advance notice of such required disclosure