North Carolina DOR: Gain on sale of partnership interest allocable income under unitary business principle

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Taxpayer is a Texas limited partnership taxed as a corporation for federal and state tax purposes. The taxpayer and an affiliated corporation jointly operated an automobile consumer finance business, which engaged in operations in many states, including North Carolina. In August of 2000, the taxpayer and the affiliated corporation contributed all of their interests in the automobile consumer finance business to a limited partnership. Subsequent to the contribution, the taxpayer owned approximately 36 percent of the new limited partnership, which was the taxpayer's only asset.


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