TAX STRATEGIES FOR CORPORATE ACQUISITIONS,

The result would be the same if B transferred goodwill to A/B in a sale transaction or a disguised sale under section 707(a)(2)(B). Because A gets its share of the partnership's cost basis under section 1012, and not section 732, 734 or 743, the determination of relatedness for purposes of the anti-churning rules is made at the partnership level. ................
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