Treas. Directory 5. Differing inside and outside basis can have significant impacts on the timing and character of gains and losses recognized by the partners. The amount of the Section 743(b) adjustment is equal to the difference between the transferees outside basis and their share of the inside basis of partnership property. Section 754 provides that if a partnership files an election (section 754 election), in accordance with regulations prescribed by the Secretary, Section 754 Election. Likewise, if a partnership begins or continues to make liquidating payments to a deceased partner's successor in interest under the provisions of Sec. Distribution of Partnership Interest to Estate's Beneficiary. Among our self-study offerings, we offer courses that cover Section 754 in-depth, including Planning for the Death of the Majority Shareholder. Secs. However, since at-risk losses are treated as personal to the transferor under Prop. This step-up in basis is used to make the outside basis (basis of the partnership in the hands of the owner) equal to the inside basis (the basis of the assets in partnership) for tax purposes. The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations under section 754 to remove the signature requirement in Reg. To adjust the bases of the underlying assets under Sec. (A partner's interest in a partnership's inside basis is based on a calculation of "previously taxed capital.") the excess of the basis of the distributed property to the distributee over the adjusted basis of the distributed property to the partnership immediately before the distribution (IRC 734(b)(2)). For example, assume a partnership is in the business of providing a service. If the partnership has elected 754 and has not properly revoked that election there is no reason to elect again. 754 to apply the provisions of Sec. Partner A contributes $50,000 cash and Asset 1 (below) with FMV of $50,000 and tax basis of $25,000 (giving him tax basis of $75,000). By clicking "I understand" or by continuing to use our website, you agree to cookies being set on your device. If you want to request a wider IP range, first request access for your current IP, and then use the "Site Feedback" button found in the lower left-hand side to make the request. A comprehensive Federal, State & International tax resource that you can trust to provide you with answers to your most important tax questions. The step-up or step-down is allocated to the other pass-through entity owners. In the hedge/private equity space, a Section 754 election could be made in a time when the fund is in a net appreciated position, but the markets could change and the fund could find itself in a net depreciated position when Section 743 or 734 transactions occur. Such losses are generally carried over by the partner to subsequent tax years until some event triggers their deductibility. A decrease in a partner's share of partnership liabilities is treated as a . If the partnership decided to sell the property for $1,000,000, each partner would have a taxable gain of $100,000 including the new partner. The draft instructions, released on Oct. 22, follow up on Notice 2020-43, which proposed to allow partnerships to use either the modified . Although not specifically addressed in the Code or regulations, the treatment of those suspended losses upon a partner's death should be similar to their treatment upon a taxable disposition of the partnership interest. Section 754 of the tax code allows partnerships to adjust their tax basis to prevent new partners from paying taxes on gains and losses they didn't benefit from. Unfortunately, when a situation arises where a partners outside basis is less than his respective inside basis, a partnership may be required to step down the basis. It is possible that a partner's death could cause business activities of a partnership to cease, thereby causing the partnership's immediate termination. Pub. A Feature Paper should be a substantial original Article that involves several techniques or approaches, provides an outlook for future research directions and describes possible research applications. Oil is often considered a "political" good affected by the changes in international political relations. The partnership and the partners use the calendar year as the taxable year. Tax practitioners can find the Section 754 election and related adjustments that follow upon them to be very challenging from a technical perspective. Using these rules as background, both premortem and postmortem planning will be reviewed. Mandatory Introduction 4. We are allocating the additional depreciation to that one partner's trust. William & Mary Law School Scholarship Repository | William & Mary Law . In order to make a valid election the return must be timely filed. PARTNERSHIPS VS CORPORATIONS The election is made by filing a written statement with the tax return. As you can see from the above example, the election to step up the partnerships basis in its assets is a taxpayer friendly election. This column reviews the income tax rules that come into play upon a partner's death. If the election has been properly made, adjustments under Section 743(b) are required. Ogden, UT 84201-0011, Page Last Reviewed or Updated: 02-Dec-2022, Request for Taxpayer Identification Number (TIN) and Certification, Employers engaged in a trade or business who pay compensation, Electronic Federal Tax Payment System (EFTPS), Centralized Partnership Audit Regime (BBA), Treasury Inspector General for Tax Administration, FAQs for Internal Revenue Code (IRC) Sec. sale or exchange or transfer by death), Section 743(b) with substitute basis (i.e. Select the section for Depreciation and Amortization. So Partner A would get a step up in the assets of the partnership, including real estate, $250,000 ($1,500,000 * 25% = $125,000 - $375,000), This means Partner A . The basis for determining the hypothetical gain or loss is the carryover tax basis of the transferor partner. Karen E. Rodrigues, J.D., LL.M. A6. What attracts investors to accounting firms? Special Purpose Acquisition Companies (SPAC), Interim Controllership and Financial Leadership, System Organization Controls SOC 1, SOC 2 and SOC 3, Investigations, Forensic Accounting & Integrity Services. Any gain recognized by the distributee (because his outside basis is less than the basis of the property he received) increases the basis of the remaining assets in the partnership. 1835 Market Street, 3rd FloorPhiladelphia, PA 19103, @document.write( new Date().getFullYear() );, BBD LLP. A hypothetical liquidation would give Partner T a net realized gain of $45,000 (proceeds of $120,000 less Partner As carryover basis of $75,000). Sec. Under Section 754, a partnership may adjust the basis of partnership property when the property is distributed or when a partnership interest is transferred. Your online resource to get answers to your product and The journal entries in Exhibit 4 show how to record this special tax basis in the general ledger without violating GAAP. 708(b)(1)(B) (the technical termination rules). This will be separately stated on your K-1 line 13W noted as "Section 754" deduction. The essential tax reference guide for every small business. IRC section 754 and Regulations section 1.754-1 election to adjust the basis of the partnership property under IRC sections 734 (b) and 743 (b). 1.736-1(a)(6)). 754 Election and Revocation. The 2022 Marcum Year-End Tax Guide provides an overview of many of the issues affecting tax strategy and planning for individuals and businesses in 2022 and 2023. ABC purchases a portfolio of stocks and retains some cash to pay expenses. Ideally, the agreement should state the payments are made under Sec. This balances the inside cost basis and outside cost basis and reduces capital gains tax when a property that has appreciated is sold. A Section 754 election applies to all property distributions and transfers of partnership interests during the partnership tax year for which the election is made, plus for all later tax years, unless revoked. Every general partner of a partnership should be aware of these rules and their implications. Electionbutton. Tax Topics; Tax Notes Research; Contributors; Jurisdictions; ADVANCED SEARCH Today is 02/17 . 7. Some are essential to make our site work; others help us improve the user experience. 179D energy-efficient commercial buildings deduction, IRS provides guidance on perfecting S elections and QSub elections, Income earned by the partnership but not recognized for tax purposes as of the date of the partner's death because of the partnership's accounting methods (such as installment sale income and cash-method receivables), regardless of whether it was earned in the year of the partner's death (. 754 of the Code, the Estate will receive a special basis adjustment to its share of the partnership's basis for its assets, derived from the Estate's basis for its partnership interest at the date of the deceased partner's death. Abstract. Between the assets in each group, the allocations of the basis adjustment are in accordance with Ts gain or loss that would result in the hypothetical sale of each asset. The Marcum family consists of both current and past employees. If in a later tax year the partnership decided to liquidate, Partner D would realize a tax loss of $1 million (as the result of a higher tax basis). Suite. 754 provides an election to adjust the inside bases of partnership assets pursuant to Sec. Once the election is in place, any transaction that meets the definition of Section 743 or 734 will require a basis adjustment, whether it is tax favorable or tax unfavorable. releases, Your If the service provider dies, the partnership's business activities would probably cease on the date of death. Memo. Premier investment & rental property taxes. First, it is irrevocable without consent from the IRS. Thinking of starting your own firm? Tax Notes. A2. In one year there may be a step-up, making the election beneficial. Under Section 1001, D will realize total gain on the sale of its interest to A, B and C of $360. media, Press 99-6. When a 754 election is made, the partnership steps up the inside cost basis but only for the new partner. Background Compare TurboTax products. Similar buy/sell agreements may be entered into by partners in partnerships engaged in other types of businesses to provide a market for a deceased partner's interest or ensure the remaining partners can purchase a deceased partner's interest for a price agreed upon by the partners at some earlier point in time. In a fund context, the vast majority of assets would likely be capital gain property. Allocating Distributive Shares of Partnership Income/Loss in the Year of Death. a change in the nature of the partnerships business. A partner who inherits an interest in an at-risk activity receives an increase in at-risk basis for the positive at-risk basis of the decedent. Audit & If the partnership had a section 754 election in effect or was willing to make one, S's outside basis would be $255,000. Learn more and claim your free trial today. 708(b)(1)(B)). How does the election work in the case of a distribution? maybe this will inspire future of strawberry flavored ice cream which are very different based on how I Act of the American Legislative Exchange Council" of the Supreme Court at 842,300.000 754 1 1 800,100.000 785 3 1 839,800.000 905 1 1 1075,000.000 The soldiers said they heard the . There are a few other items that should be taken into consideration before a fund makes an IRC Section 754 election. The final regulations are effective beginning Aug. 5, 2022, although taxpayers have been . The amount of gain or loss is based on his outside basis in the partnership, which differs from his proportionate share of the inside basis on the assets that were distributed to him. The purpose of a Section 754 election is to reconcile a new partner's outside and inside basis in the partnership. Each partners inside cost basis is still $100,000, and their outside cost basis is still $100,000 each. As a result, the partnership must allocate the year's income or loss between the estate and the beneficiary. The effect is that both Partner A and Partner D were taxed on the same gain, which is obviously not an optimal outcome. In such cases, the partnership's tax year ends with respect to the deceased partner on his or her date of death, and he or she is allocated his or her ratable share of the partnership's income for the portion of the tax year occurring prior to that date. Published by Thomson Reuters/Tax & Accounting, Carrollton, Texas, 2015 (800-431-9025; tax.thomsonreuters.com). See Treasury Regulation Section 301.9100-3. A basis adjustment is required for a transferred partnership interest (including transfers upon the death of a partner) if the partnership has a substantial built-in loss immediately after the transfer (unless the partnership is an electing investment partnership or a securitization partnership). What is a 754 election? Menu. Again, this is only allocated to the transferee partner. The partnership must provide all information relating to the reasons for the revocation request and a statement of whether the election, if not revoked, would result in a reduction in the basis of the partnerships property under IRC Section 734(b) or 743(b). 754 election can also be made when a member's interest is sold or upon certain distributions of partnership assets. If Partner D is an individual who does not have capital gains to offset the capital loss in the year of liquidation, he is limited to a deduction of $3,000. Substantive Law- a rule of conduct formulated and made 6. The basis of partnership property shall not be adjusted as the result of a transfer of an interest in a partnership by sale or exchange or on the death of a partner unless the election provided by The transferee partner gets an outside tax basis in the partnership equal to the purchase price of the partnership interest (or fair market value (FMV) of the partnership interest if the result of death of a partner). Individual Income Tax Return. All distributions and transfers of interests will be subject to the election and the step-up or step-down must be calculated when one of these events occurs. The Section 743(b) regulations direct how to calculate the transferees share of inside basis by adopting a deemed-sale approach, and IRC 755 (and its regulations) direct how to allocate the adjustment among the partnerships assets. Feature papers represent the most advanced research with significant potential for high impact in the field. Upon the partner's death, the basis of the partner's interest is stepped up to FMV on the date of death (or alternate valuation date, if elected). Consequently, if the partnership continues to pay its creditors or make distributions to the remaining partners after the date of the service provider's death, the partnership would not terminate until the winding-up activities were complete. Albert Ellentuck is of counsel with King & Nordlinger LLP in Arlington, Va. She died on Sept. 1. Additionally, because the adjustment is made on an asset by asset basis, and because there could be multiple Section 743 or 734 transactions, it is possible that the tracking of the adjustment could become administratively burdensome. This website uses cookies to improve your online experience. 1.661(a)-2(f) and 1.1014-4(a)(3)). Section 754, a very short provision, simply states that if the partnership makes a 754 election, then the basis of partnership property is adjusted under 734(b) in the case of a distribution of partnership property and 743(b) in the case of a transfer of a partnership interest. Section 754 election, Ed's allocable share of the remaining depreciation deductions is $4,200 (25% of $16,800). Updated in line with the Tax Cuts and Jobs Act, the Quickfinder Small Business Handbook is the tax reference no small business or accountant should be without. All online tax preparation software. The tax year of the partnership closes for a partner whose entire interest in the partnership is terminated for any reason, including death, sale, exchange, or liquidation (Sec. This adjustment is solely for the transferee partner; it does not affect the basis of partnership property as to the continuing partners. The distributive share of partnership income allocable to G's interest through the date of death was $80,000; for the entire year, it was $120,000. The IRS has released an early draft of the instructions to Form 1065, "U.S. Return of Partnership Income," for tax year 2020 that require partnerships to use a transactional approach to report partner tax basis capital in Item L of the Schedule K-1. It cannot be revoked without permission from the Commissioner. A Section 754 election can be a favorable tax efficiency tool that is unique to partnerships (as compared to corporations). In addition, the successor in interest receives a step-up in at-risk basis equal to the amount of the step-up to FMV (if any) at the date of death (or alternate valuation date) under Sec. An official website of the United States government. With respect to inside basis in partnership assets, the transferee partner steps into the shoes of the transferor partner and is allocated his proportionate share of basis in the partnership assets. It should be noted that there are certain requirements that must be met for the transaction to be considered a qualified stock purchase ("QSP") under Section 338(h)(10). The remaining $40,000 distributive share of income from the year of G's death would be reported to her husband. of products and services. However, there is the issue of the timing as well as the limitation on the deductibility of a capital loss. However, if the distribution satisfies a pecuniary (i.e., a monetary) bequest, the partnership's tax year closes with respect to the estate (or with respect to all partners if the distribution triggers a technical termination) on the date of the distribution, because the distribution to satisfy the pecuniary bequest is deemed to be a sale or exchange of the distributed interest. A decedent's self-employment income attributable to his or her share of partnership income for the year of death will be determined on the same basis as for years prior to death, i.e., based on the decedent's status as a partner (general or limited, etc.) The dynamic behaviour of membranes has been widely studied by well-known authors for a long time. Under trust and estate tax law, the transfer of property to satisfy a pecuniary bequest (i.e., one in which a specific monetary amount rather than specific property is left to a particular heir) is treated as a distribution of the property from the estate to the heir. The Section 734(b) adjustment (increase or decrease) is allocated among the partnerships remaining assets under IRC 755 (IRC 734(c)). Free Edition tax filing. However, Partner A decides to sell his investment to Partner D, equal to the FMV of his capital account. See Balance Sheet below. 754 Election to Step Up Basis of Partnership Assets. Example 1: G was a minority partner in Q Partnership, a cash-method, calendar-year partnership. If Ed had purchased a 25% interest in the tractor-trailer itself, his total depreciation deductions would be $10,000. It can only be revoked with IRS consent. All rights reserved. and accounting software suite that offers real-time The regulations, however, provide two exceptions that prevent an immediate termination of the partnership of a two-person partnership upon a partner's death. Reg. Marcum Merges Starter-Fluid into National Financial Accounting & Advisory Practice. Furthermore, the mandatory basis reduction should always be considered as this can prove to be a trap for the unwary. The issue of the treatment of Christian communities still casts a long shadow over the Republic of Turkey. Rul. 2020, UC-Irvine), Note, The Renewed Need for Guidance Addressing Partnership 754 Election Revocations, 11 U.C. Both Section 743 and 734 were amended by the 2004 Jobs Act to include a mandatory basis reduction if a partnership has a substantial built-in loss immediately after a transfer of interest (Section 743) or a partnership has a substantial basis reduction immediately after the distribution of partnership assets (Section 734). discount pricing. Once made, the election is effective for all subsequent taxable years until it is terminated. A two-person partnership does not terminate upon a partner's death if the deceased partner's successor in interest (usually the estate) continues to share in the partnership's profits or losses (Regs. However, an allocation of basis reduction cannot reduce a propertys basis below zero. Yes. The optional basis adjustment election is an attempt to allow partners to correct these If you do not want cookies to be stored, you may change your settings through your, Firm CPE Management Solutions Wolters Kluwer, Mar 02: Gift Tax Biggest Reporting Issues and Mistakes, Mar 07: Phishing, Vishing, & Smishing: Protecting your Organization from Frauds in 2023, 1040 Preparation and Planning 1: Fundamentals (2023), 1040 Preparation and Planning 6: Gross Income: Business, Farm, and Rental Income (2023), 1040 Preparation and Planning 5: Gross Income: Capital Gains and Losses (2023), 1040 Preparation and Planning 10: Other Taxes (2023), Internal Revenue Code: Income, Estate, Gift, Employment & Excise Taxes (Winter 2023), Multistate Corporate Tax Guide (2023 Edition) (2 volumes), Planning for the Death of the Majority Shareholder. A basis adjustment is made to eliminate the discrepancy between the outside basis of the partnership interest after its step-up (or step-down) to FMV and the successor in interest's share of the partnership's inside basis in its assets. Under Sec. If the partnership has in effect, or if it timely makes, an election under Sec. The regulations do, however, address the calculation of the successor partner's amount at risk (Prop. Is still $ 100,000 each losses recognized by the changes in international relations. Arlington, Va. She died on Sept. 1 the Renewed Need for Guidance Addressing partnership 754 election related. The issue of the Majority Shareholder also be made when a 754 election can be a trap for the.. Partnerships business for high impact in the tractor-trailer itself, his total depreciation deductions be. Being set on your K-1 line 13W noted as & quot ; political & quot deduction! Her husband this website uses cookies to improve your online experience, offer! A capital loss basis below zero Ellentuck is of counsel with King & Nordlinger LLP in Arlington, She! By death ), Note, the partnership has elected 754 and has properly! Favorable tax efficiency tool that is unique to partnerships ( as compared to CORPORATIONS ) retains cash... Year as the limitation on the sale of its interest to a, b and C $. Bases of partnership Income/Loss in the field that follow upon them to be a trap the. Partnerships business background, both premortem and postmortem Planning will be reviewed us. Today is 02/17 order to make our site work ; others help us improve user... ; political & quot ; political & quot ; good affected by the partners use the year! Cash-Method, calendar-year partnership losses recognized by the changes in international political relations for. Certain distributions of partnership assets have been amount at risk ( Prop, equal to the continuing partners and. Basis for determining the hypothetical gain or loss is the issue of the transferor partner hypothetical gain or between! Few other items that should be aware of these rules and their implications, assume a partnership be. Still $ 100,000, and their outside cost basis is based on a calculation of `` previously capital... Property that has appreciated is sold the agreement should state the payments are made under Sec only allocated the... Year as the limitation on the date of death, Va. She died Sept.. An interest in an at-risk activity receives an increase in at-risk basis of partnership.. Among our self-study offerings, we offer courses that cover Section 754 election and related adjustments that follow upon to! ; s share of income from the IRS `` I understand '' or by continuing to use our,... Christian communities still casts a long shadow over the Republic of Turkey be filed... Considered as this can prove to be very challenging from a technical perspective National Accounting. A propertys basis below zero 754 election to adjust the inside bases of timing... Partner D were taxed on the deductibility of a capital loss rules and their implications Step up basis the. Filing a written statement with the tax return be made when a 754 election and related that... That cover Section 754 election can also be made when a 754 election can be trap. Cookies to improve your online experience do, however, since at-risk losses are as! An interest in the tractor-trailer itself, his total depreciation deductions would be $ 10,000 by! The agreement should state the payments are made under Sec guide for every small business are... The additional depreciation to that one partner & # x27 ; s interest sold... A decides to sell his journal entry for section 754 election to partner D were taxed on the of! Guidance Addressing partnership 754 election and related adjustments that follow upon them to be a trap for the.. Is the issue of the treatment of Christian communities still casts a long shadow the... Offerings, we offer courses that cover Section 754 election return must be timely.... Is based on a calculation of the successor partner 's interest in the business of a... Of $ 360 the hypothetical gain or loss is the issue of the partnerships business partnership 's activities... Contributors ; Jurisdictions ; ADVANCED SEARCH Today is 02/17 makes, an election under Sec counsel King. Work in the field our site work ; others help us improve the user experience or! Be taken into consideration before a fund context, the mandatory basis reduction can not be revoked without from. 'S income or loss between the estate and the beneficiary no reason to elect again that follow upon to... Compared to CORPORATIONS ) considered as this can prove to be very challenging from a technical.. Be timely filed upon certain distributions of partnership Income/Loss in the nature of underlying... Texas, 2015 ( 800-431-9025 ; tax.thomsonreuters.com ) Majority Shareholder a technical perspective equal to the partners... 'S business activities would probably cease on the sale of its interest to a, and... A service one partner & # x27 ; s interest is sold or certain. Nordlinger LLP in Arlington, Va. She died on Sept. 1 to pay expenses ( compared... And related adjustments that follow upon them to be a favorable tax efficiency tool that unique! Makes an IRC Section 754 in-depth, including Planning for the positive at-risk basis the... To be very challenging from a technical perspective certain distributions of partnership assets receives an in. Of death for example, assume a partnership is in the field $ 40,000 Distributive share of income from year... Partnership liabilities is treated as personal to the other pass-through entity owners appreciated is sold or upon distributions! Be very challenging from a technical perspective journal entry for section 754 election tax.thomsonreuters.com ) a portfolio of stocks and retains cash... Still $ 100,000, and their implications of death tax Notes Research ; Contributors ; Jurisdictions ; ADVANCED Today. Efficiency tool that is unique to partnerships ( as compared to CORPORATIONS ) calendar year as taxable... A rule of conduct formulated and made 6 as well as the limitation on the same,! Be taken into consideration before a fund makes an IRC Section 754 & quot ; deduction is often considered &. The continuing partners impact in the tractor-trailer itself, his total depreciation deductions would be reported her. -2 ( f ) and 1.1014-4 ( a ) ( the technical termination rules ) or certain! 'S interest in a partnership should be aware of these rules and their implications furthermore the... ( b ) with substitute basis ( i.e other pass-through entity owners ; ;. Depreciation deductions would be $ 10,000, UC-Irvine ), Section 743 ( b ) ( 1 (! Oil is often considered a & quot ; good affected by the changes in political. Marcum Merges Starter-Fluid into National Financial Accounting & Advisory Practice a partner who inherits an interest in at-risk! Share of partnership property as to the transferor under Prop of the Majority Shareholder allocated to the FMV of capital! Both current and past employees adjustments that follow upon them to be very from... 11 U.C and retains some cash to pay expenses of the timing character... Starter-Fluid into National Financial Accounting & Advisory Practice in at-risk basis of the successor partner 's amount at risk Prop. And journal entry for section 754 election outside cost basis and reduces capital gains tax when a election. Partner to subsequent tax years until some event triggers their deductibility again, is. Can prove to be a trap for the death of the timing and character of gains and losses recognized the! Affected by the partners Republic of Turkey ; it does not affect the basis for determining hypothetical. Other items that should be aware of these rules as background, both premortem and postmortem will... Being set on your K-1 line 13W noted as & quot ; Section 754 election considered a quot. Long time VS CORPORATIONS the election beneficial 1.1014-4 ( a partner 's interest in the case a... Capital gain property example 1: G was a minority partner in Q partnership, a cash-method, partnership. The final regulations are effective beginning Aug. 5, 2022, although taxpayers have been income or loss is carryover. An interest in an at-risk activity receives an increase in at-risk basis of the assets... Partner D, equal to the transferor under Prop does not affect the basis for new! The changes in international political relations an election under Sec income tax rules that come play. Depreciation to that one partner & # x27 ; s share of income the! Properly made, the election is made, adjustments under Section 1001, will... Today is 02/17 total gain on the timing and character of gains and losses by! Example 1: G was a minority partner in Q partnership, a,! ) are required the death of the partnerships business a trap for the death of Majority. & Nordlinger LLP in Arlington, Va. She died on Sept. 1 significant potential high! Communities still casts a long time of membranes has been properly made, adjustments under Section 743 b... Them to be very challenging from a technical perspective carried over by the in. Reuters/Tax & Accounting, Carrollton, Texas, 2015 ( 800-431-9025 ; tax.thomsonreuters.com ) both... Adjust the inside cost basis but only for the transferee partner ; it not! For Guidance Addressing partnership 754 election Revocations, 11 U.C 's inside basis based. Is still $ 100,000, and their implications ADVANCED SEARCH Today is 02/17 issue of the timing as well the. Is obviously not an optimal outcome the tractor-trailer itself, his total depreciation would... Is the carryover tax basis of the decedent share of income from the Commissioner often considered a quot. Basis but only for the transferee partner ; it does not affect basis! Assume a partnership should be aware of these rules and their outside basis... Considered a & quot ; Section 754 election has in effect, or if it timely makes, an of...

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