Page:United States Statutes at Large Volume 68A.djvu/293

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CH, 1

NORMAL TAXES AND SURTAXES

253

agreement made prior to, or at, the time prescribed by law for the filing of the partnership return for the taxable year (not including extensions) which are agreed to by all the partners, or which are adopted in such other manner as may be provided by the partnership agreement. (d) LIQUIDATION OF A P A R T N E R ' S INTEREST.^—For purposes of this subchapter, the term "liquidation of a partner's interest" means the termination of a partner's entire interest in a partnership by means of a distribution, or a series of distributions, to the partner by the partnership. PART IV—EFFECTIVE DATE FOR SUBCHAPTER Sec. 771. Effective date. SEC. 771. EFFECTIVE DATE. (a) GENERAL RULE. — (1) T A X A B L E Y E A R S

BEGINNING

AFTER

DECEMBER

31, 1954.—

Except as provided in subsection (b), this subchapter shall apply with respect to— (A) any partnership taxable year beginning after December 31, 1954, and (B) any part of a partner's taxable year falling within such partnership taxable year. (2) APPLICATION OF PRIOR PROVISIONS.—Except as provided in

subsection (b), sections 113(a) (13), 181 to 191 (inclusive), and 3797 (a)(2) of the Internal Revenue Code of 1939 shall apply with respect to— (A) any partnership taxable year beginning before January 1, 1955, and (B) any part of a partner's taxable year falling within such partnership taxable year. (b) SPECIAL RULES. — (1) ADOPTION OF TAXABLE YEAR.—Section 706(b) (relating to

the adoption of a taxable year by a partnership or partner) shall apply to— (A) any partnership which adopts, or changes to, a taxable year beginning after April 1, 1954, and (B) any partner who changes to a taxable year beginning after April 1, 1954. For the purpose of applying this paragraph, section 708 (relating to the continuation of a partnership) shall be effective for taxable years beginning after April 1, 1954. (2) PROPERTY DISTRIBUTED BY A PARTNERSHIP.—Section 735(a)

(relating to the character of gain or loss on the disposition of property distributed by a partnership) shall apply only to property distributed by a partnership after March 9, 1954. (3) UNREALIZED RECEIVABLES AND INVENTORY ITEMS.—Section

751 (relating to unrealized receivables and inventory items) shall apply with respect to gain or loss to a seller, distributee, or partnership in the case of a sale, exchange, or distribution occurring after March 9, 1954. For the purpose of applying this paragraph in the case of a taxable year beginning before January 1, 1955, the other §771(by(3)