In applying the § 318 stock attribution rules to a stock redemption, the stock of a partnership is deemed to be owned proportionately by its partners.

Question

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Under § 318 of the Internal Revenue Code, the stock attribution rules indeed treat the stock owned directly or indirectly by or for a partnership as being owned proportionately by its partners for the purpose of determining stock ownership in various tax contexts, including stock redemptions.

In Applying the § 318 Stock Attribution Rules to a Stock