A §754 election is made by a distributee partner for a tax year in which (1) the distributee partner recognizes gain or loss on a distribution from a partnership or (2) the distributee partner's basis in distributed assets differs from the partnership's inside basis in those assets.
A §754 election is made by the partnership.

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A §754 election is made by the partnership, not by an individual distributee partner. It allows the partnership to adjust the basis of its assets in certain situations, such as distributions or transfers of partnership interests.

A §754 Election Is Made by a Distributee Partner for a Tax