...delivered, of to be delivered, to the extent the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or "(2) services rendered, or to be rendered." J0° Subsection (d) of section 751 originally read as...

...attributable to unrealized receivables of the partnership, or inventory items of the partnership that have appreciated substantially in value, shall be...or exchange of property other than a capital asset. Under section 1.751-1 (a) (1) of the Income Tax Regulations, to the extent that money or property received...

...the partnership, or (2) Inventory items of the partnership which have appreciated substantially lz» value, shall be considered as an amount realized from...or exchange of property other than a capital asset. (b) Certain distributions treated as sale* or exchanges — (1) General rule. To the extent a partner...

...part of such partner's interest in the partnership attributable to section 751 property, is considered an amount realized from the sale or exchange of property other than a capital asset. Thus, any gain or loss attributable to the sale or exchange of section 751 property would be ordinary...

...delivered, or to be delivered, to the extent the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or services rendered, or to be rendered. Thus, since the amounts paid to C, other than the amounts...

...income". (D) Paragraphs (1) and (2) of section 735 (a) are each amended by striking out "gain or loss from the sale or exchange of property other than a capital asset" and inserting in lieu thereof ''as ordinary income or as ordinary loss, as the case may be". (E) Section...

...delivered, or to be delivered, to the extent the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or (2) Services rendered, or to be rendered. For purposes of this section and sections 731, 736, and...

...US 496 (1948). ' Sec. 751(a) provides as follows: (a) SALE OR EXCHANGE OF INTEREST IN PARTNERSHIP— The amount of any money, or the fair market value...or exchange of property other than a capital asset. accounts receivable and charges for unbilled services would have been treated as ordinary income if...

...interest in the partnership attributable to — (1) unrealized receivables of the partnership, or (21 inventory items of the partnership which have appreciated...or exchange of property other than a capital asset. "S. Rept. 1622, 83d Cong.. 2d Sess. 98 (1954); H. Kept. 1337, 83d Cong., 2d Sess. 70 (19541. "Under...

...interest was an integrated part of the sales transaction does not cause amounts received as interest to be considered as an "amount realized" from the sale or exchange of property as contemplated by section 1001 (b). Section 337. excludes from recognition the gain or loss of a liquidating...