26 C.F.R. § 1.195-2

Current through October 31, 2024
Section 1.195-2 - Technical termination of a partnership
(a)In general. If a partnership that has elected to amortize start-up expenditures under section 195(b) and § 1.195-1 terminates in a transaction (or a series of transactions) described in section 708(b)(1)(B) or § 1.708-1(b)(2) , the termination shall not be treated as resulting in a disposition of the partnership's trade or business for purposes of section 195(b)(2). See § 1.708-1(b)(6) for rules concerning the treatment of these start-up expenditures by the new partnership.
(b)Effective/applicability date. This section applies to a technical termination of a partnership under section 708(b)(1)(B) that occurs on or after December 9, 2013.

26 C.F.R. §1.195-2

T.D. 9681, 79 FR 42679 , July 23, 2014