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Recoupment by a Partner Pursuant to the Disposal of a Partnership Interest
The question whether there can ever be a recoupment by a partner to the extent that he disposes of his interest in a partnership as opposed to a partnership disposing of assets, has always been contentious. In this context it was always contended by taxpayers that there cannot be a recoupment to the extent that a partner disposes of a partnership interest, even though a partnership is not a separate legal entity and income that has accrued to partners in common is deemed to have accrued to each
South Africa
30 Jun 2005
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