26 U.S.C. § 723

Basis of property contributed to partnership

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The basis of property contributed to a partnership by a partner shall be the adjusted basis of such property to the contributing partner at the time of the contribution increased by the amount (if any) of gain recognized under section 721(b) to the contributing partner at such time.

Notes of Decisions

Cited in 6 cases, 2008–2016 · leading case: Superior Trading, LLC v. Comm'r, 728 F.3d 676 (7th Cir. 2013).

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Superior Trading, LLC v. Comm'r, 728 F.3d 676 (7th Cir. 2013). “26 U.S.C. §§ 723 , 1012. Recognition for tax purposes of gain or loss attributable to'any change in the asset’s value before the asset was contributed to the partnership is deferred until the partnership sells the asset.”

Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United States, 659 F.3d 466 (5th Cir. 2011). “26 U.S.C. § 723 . 10 . See 26 C.F.R. § 1.”

Cemco Investors, LLC v. United States, 515 F.3d 749 (7th Cir. 2008). “The IRS is free to determine assets’ correct basis, under governing law, whether or not a former owner has filed a creative tax return full of fanciful numbers.”

Russian Recovery Fund Ltd. v. United States, 122 Fed. Cl. 600 (Fed. Cl. 2015). “26 U.S.C. §§ 723 , 1012. Recognition for tax purposes of gain or loss attributable to any change in the asset’s value before the asset was contributed to the partnership is deferred until the partnership sells the asset.”

Russian Recovery Fund Ltd. v. United States (Fed. Cl. 2016). “26 U.S.C. §§ 723 , 1012. Recognition for tax purposes of gain or loss attributable to any change in the asset’s value before the asset was contributed to the partnership is deferred until the partnership sells the asset.”

Cemco Investors v. United States (7th Cir. 2008). “True enough, 26 U.S.C. §723 provides that Cemco’s basis in the euros must equal the basis the asset had for its last owner.”

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