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CHAPTER 1— NORMAL TAXES AND SURTAXES›Subchapter K— Partners and Partnerships›PART II— CONTRIBUTIONS, DISTRIBUTIONS, AND TRANSFERS›Subpart D— Provisions Common to Other Subparts

§ 752. Treatment of certain liabilities

26 U.S.C. Subtitle A — Income Taxes (Internal Revenue Code) · 2026 edition · updated 2026-10-03 · United States

(a) Increase in partner’s liabilities

Any increase in a partner’s share of the liabilities of a partnership, or any increase in a partner’s individual liabilities by reason of the assumption by such partner of partnership liabilities, shall be considered as a contribution of money by such partner to the partnership.

(b) Decrease in partner’s liabilities

Any decrease in a partner’s share of the liabilities of a partnership, or any decrease in a partner’s individual liabilities by reason of the assumption by the partnership of such individual liabilities, shall be considered as a distribution of money to the partner by the partnership.

(c) Liability to which property is subject

For purposes of this section, a liability to which property is subject shall, to the extent of the fair market value of such property, be considered as a liability of the owner of the property.

(d) Sale or exchange of an interest

In the case of a sale or exchange of an interest in a partnership, liabilities shall be treated in the same manner as liabilities in connection with the sale or exchange of property not associated with partnerships.

(Aug. 16, 1954, ch. 736, 68A Stat. 251.)

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▸Contents — 26 U.S.C. Subtitle A — Income Taxes (Internal Revenue Code)
26 U.S.C. Subtitle A — Income Taxes (Internal Revenue Code)

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