Tax law disparate treatment

If Joan, an individual, sells appreciated property to a partnership, she would likely recognize a taxable gain on this transaction under U.S. Federal tax law. However, if the same property was contributed to the partnership, under IRC Reg. Sec. 1.721-2(f), no gain would be recognized by Joan. Consider why the tax law provides this, seemingly, disparate treatment.

Describe a reason why you think this outcome makes sense. Please come up with a reason different than your classmates.

 

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No need for a cover page, this is for a senior level corporate tax class.  Will need a minimum of two APA creditable peer reviewed articles cited and reference, with the links to the material.  Thank you.

 

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