26 U.S.C. § 751: Unrealized receivables and inventory items

unrealized receivables of the partnership, or inventory items of the partnership, unrealized receivables, or inventory items which have appreciated substantially in value, partnership property (including money) other than property described in subparagraph (A)(i) or (ii) in exchange for all or a part of his interest in partnership property described in subparagraph (A)(i) or (ii), a distribution of property which the distributee contributed to the partnership, or payments, described in section 736(a), to a retiring partner or successor in interest of a deceased partner. Inventory items of the partnership shall be considered to have appreciated substantially in value if their fair market value exceeds 120 percent of the adjusted basis to the partnership of such property. For purposes of subparagraph (A), there shall be excluded any inventory property if a principal purpose for acquiring such property was to avoid the provisions of this subsection relating to inventory items. goods 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. property of the partnership of the kind described in section 1221(a)(1), any other property of the partnership which, on sale or exchange by the partnership, would be considered property other than a capital asset and other than property described in section 1231, and any other property held by the partnership which, if held by the selling or distributee partner, would be considered property of the type described in paragraph (1) or (2). For purposes of applying this section and sections 731 and 741 to any amount resulting from the reference to section 1248(a) in the second sentence of subsection (c), in the case of an individual, the tax attributable to such amount shall be limited in the manner provided by subsection (b) of section 1248 (relating to gain from certain sales or exchanges of stock in certain foreign corporation). an unrealized receivable, or an inventory item,