There is a misconception on what capital gains is. Capital gains tax are levied for sales of capital assets owned by individuals. It could be an asset an individual owns and uses in a business or a personal asset such as stocks and bonds, collectibles, homes etc. The key to this is that the assets are individually owned.
In your case, your partnership is a disregarded entity thus the liquidation of your partnership and assets will be treated as an ordinary gain or loss because these aren't individually owned. They are owned by the partnership.
There are no circumstances that I can think of on how to treat this as a capital gain or loss as defined by IRC 735. Please read the details here.
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