Type
PLR
Year
Summary

REIT determines its capital interest in a partnership under Treas. Reg. 1.856-3(g) by a) deeming the partnership to have made a liquidating distribution in an amount equal to the fair market value of the partnership assets, net of the partnership liabilities, and, b) computing the percentage of the deemed distribution to which the REIT would be entitled under the terms of the partnership agreement.