Sales of distributed property
For purposes of this subsection—
(A) Transfer of proceeds from sale of distributed property treated as transfer of distributed property
(A)Transfer of proceeds from sale of distributed property treated as transfer of distributed property#
The transfer of an amount equal to any portion of the proceeds from the sale of property received in the distribution shall be treated as the transfer of property received in the distribution.
(B)Proceeds attributable to increase in value#
The excess of fair market value of property on sale over its fair market value on distribution shall be treated as property received in the distribution.
(C)Designation where amount of distribution exceeds rollover contribution#
In any case where part or all of the distribution consists of property other than money—
(i) the portion of the money or other property which is to be treated as attributable to amounts not included in gross income, and
(ii) the portion of the money or other property which is to be treated as included in the rollover contribution,
shall be determined on a ratable basis unless the taxpayer designates otherwise. Any designation under this subparagraph for a taxable year shall be made not later than the time prescribed by law for filing the return for such taxable year (including extensions thereof). Any such designation, once made, shall be irrevocable.
(C)(i)#
the portion of the money or other property which is to be treated as attributable to amounts not included in gross income, and
(C)(ii)#
the portion of the money or other property which is to be treated as included in the rollover contribution,
(D)Nonrecognition of gain or loss#
No gain or loss shall be recognized on any sale described in subparagraph (A) to the extent that an amount equal to the proceeds is transferred pursuant to paragraph (1).