PARTNERSHIPS MAY RELY ON PROPOSED DISGUISED-SALE REGS FOR SOME TRANSACTIONS.

Notice 92-46

The Internal Revenue Service published final regulations under section 707(a)(2) of the Internal Revenue Code on September 30, 1992. A partnership and its partners may rely on the proposed regulations, published April 25, 1991 (56 Fed. Reg. 19055), for any transaction with respect to which all transfers considered part of a sale occur after April 24, 1991, if at least one of the transfers considered part of a sale occurs before November 30, 1992.

The principal author of this notice is J. Scott Hargis of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this notice contact J. Scott Hargis or Susan T. Edlavitch on (202) 622-3050 (not a toll-free call).