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Agree.

1) As I advised earlier, the formation of a new fund to make an acquisition is not in and of itself a device for avoidance, unless the new fund has the same members, pro-rata, as the existing fund...

1) 802.30 would apply to the UPE that currently holds the assets, but not the other UPE 2) You would look at the used durable good exemption - 802.1(d)

You can deduct the undeveloped property and the 300 acres of land, but not the grapevines or the winery.

You can deduct the undeveloped property and the 300 acres of land, but not the grapevines or the winery.

1) 802.30 would apply to the UPE that currently holds the assets, but not the other UPE 2) You would look at the used durable good exemption -§ 802.1(d)

1) As I advised earlier, the formation of a new fund to make an acquisition is not in and of itself a device for avoidance, unless the new fund has the same members, pro-rata, as the existing fund...

Agree.

Agree not reportable.

Agree – not reportable.