(a) In general. If a partnership that has elected to amortize start-up expenditures under section 195(b) and §1.195-1 terminates in a transaction (or a series of transactions) described in section 708(b)(1)(B) or §1.708-1(b)(2), the termination shall not be treated as resulting in a disposition of the partnership's trade or business for purposes of section 195(b)(2). See §1.708-1(b)(6) for rules concerning the treatment of these start-up expenditures by the new partnership.

(b) Effective/applicability date. This section applies to a technical termination of a partnership under section 708(b)(1)(B) that occurs on or after December 9, 2013.

[T.D. 9681, 79 FR 42679, July 23, 2014]