Sale of Partnership Interest, including but not limited to:

• Allocating purchase price to the Code Section 1060 asset categories;
• Shoving as much as possible in the allocation into capital gain assets for sellers and to ordinary income for purchasers;
• Installment sales of partnership assets;
• 754 elections with 743 and 734 book up / down of inside basis and allocation under 755;
• Book up of 704(b) capital accounts and tracking thereafter to prevent equity shifts;
• Closing a partnership taxable year; 
• Contingent consideration in the sale of partnership interest;
• Transfers of assets to and from partnerships and analyzing and structuring around the disguised sale rules; and
• Allocating income in the year of change.