Liquidating dividend example

The units are first held for sale on January 1, 1996, and the last unit is sold on December 31, 1996.This paragraph (c)(2)(v) provides that holding an interest in property in a dealing activity (the marketing of the property) is treated for purposes of § 1.469-2T(c)(2) as the use of the interest in a nondealing activity if the marketing of the property is incidental to the nondealing use.A acquires a building on January 1, 1993, and uses the building in a trade or business activity in which A materially participates until March 31, 2004. Assuming A's lease of the building to B constitutes a rental activity (within the meaning of § 1.469-1T(e)(3)), the building is used in a passive activity for 21 months (April 1, 2004, through December 31, 2005).

An entity is similar to a C corporation for this purpose if the owners of interests in the entity derive only portfolio income (within the meaning of § 1.469-2T) from the interests.

X acquires a building on January 1, 1993, and sells the building on March 1, 1994.

At the time of the sale, A's interest in the building held through X is substantially appreciated (within the meaning of paragraph (c)(2)(iii)(C) of this section).

The building is leased to various tenants at all times during the period in which it is held by X.

Assume that the lease of the building would constitute a rental activity (within the meaning of § 1.469-1T(e)(3)) with respect to a person that holds the building directly or through an S corporation.

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