267(a)In general
(1)Deduction for losses disallowed
No deduction shall be allowed in respect of any loss from the sale or exchange of property, directly or indirectly, between persons specified in any of the paragraphs of subsection (b)
(b)Relationships
The persons referred to in subsection (a) are:
(1)Members of a family, as defined in subsection (c)(4)
(c)Constructive ownership of stock
For purposes of determining, in applying subsection (b), the ownership of stock—
(4)The family of an individual shall include only his brothers and sisters (whether by the whole or half blood), spouse, ancestors, and lineal descendants;
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PLR-111089-00
The section 267 constructive ownership rules for stock are extended to partnership interests by section 267(e)(3), which provides, in relevant part, that for purposes of determining ownership of a capital interest or profits
interest of a partnership, the principles of section 267(c) (the stock constructive
ownership rules) shall apply
you don't mention what the other lines of the k-1 show but for the year of sale a prorated amount of profit or loss should have been reflected on the k-1 either using the per share per day or specific cutoff methods. also, a final return should have been filed for 2021. There can't be a one-person partnership. the IRS requires that there be interest included with the installment payments which are reportable in the year received. finally, the k-1 still shows you as a partner. this will be in conflict with your 2021 and 2022 returns. even though it was an installment sale you ceased being a partner/memeber on the ate you old regardless of the installment sale.
