The United States Tax Court has held that section 741 of the Internal Revenue Code controls the characterization of the loss from the sale or exchange of a partnership interest; that section acts independently of section 1221, and therefore the taxpayer may not avail himself of the Corn Products doctrine.
Pollack v. Commissioner, 69 T.C. 142 (1977).
William E. Kelleher Jr.,
Federal Income Tax - Sale or Exchange of Partnership Interest - Capital Loss - Corn Products,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol17/iss1/18