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in revenue ruling 87 dash 110 Corp X owned fifty percent of the XZ partnership Corp X entered into a tax-free reorganization with corp y as part of the reorganization corvex transferred all of its assets to corp why in exchange for corp livestock after the reorganization Corp why owned the fifty percent interest in the XZ partnership the transfer by Corp X of the partnership interest was in exchange for purposes of section 7008 B 1 B unless the reorganization qualified as an F reorganization if the reorganization was not an F reorganization the transfer of the partnership interest caused a technical termination of the partnership a technical termination of a partnership causes the partnerships tax year to end among other things