Some additional facts would be helpful, but I don't believe any Section 754 election needs to be made even with the limited facts.
- If the partnership was A and B, did either A or B purchase the other membership units to become the sole owner?
- If the partnership was A and B, did C purchase all the units to become the sole owner?
- What type of assets did the partnership have; fixed assets, inventory, receivables, payables, method of accounting?
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
