journal entry for section 754 election

corporations. Premier investment & rental property taxes. Awesome. As to a transfer of a partnership interest, the basis of partnership property is adjusted in accordance with IRC 743(b) if the partnership makes a Section 754 election or already has one in place. A Sec. When a partnership is formed, the inside cost basis and outside cost basis for an asset are usually the same. 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. ; Go to Form Sch K-1 (1065). Section 734 Distribution of partnership assets to a partner. ABC purchases a portfolio of stocks and retains some cash to pay expenses. These adjustments are more common with hedge funds and private equity funds. Pre-Sale Process Succession Planning for Business Owners Business and Tax Planning Fundamentals, Including the Impact of COVID-19 Our experience representing sellers prior to the outbreak of COVID-19 was that financial buyers generally included rollover equity as part of their transaction structure. 754 Election to Step Up Basis of Partnership Assets. . A partnership wishing to revoke the election must file a request on Form 15254, Request for Section 754 Revocation, no later than 30 days after the close of the partnership year for which the revocation is intended to take effect. Treatment of Suspended Losses Upon Partner's Death. These are defined as follows: This is the basis of an asset owned by a partnership, or the price paid for an asset at the time of acquisition. If more than 12 months have passed, late relief can still be requested but must be approved by the Commissioner. If a Section 754 election is made or in effect at the time of X's purchase of A's interest, the partnership is permitted to increase the basis of its land by the excess of: X's outside basis. A 754 election has been made for a partnership for a step up A 754 election has been made for a partnership for a step up basis for a partner and all the depreciation for the newly created assets has read more PDtax CPA, MBA Master's Degree 8,265 satisfied customers We have a small LLC that owned a rental property that we A Section 754 election can be a favorable tax efficiency tool that is unique to partnerships (as compared to corporations). The Section 754 election can also apply when a partnership makes a distribution of property and the basis of the distributed property to the partnership and the basis the partner/distributee will take in the distributed property are not equal. partnership's request for extension to file a late 754 election. Self-employed taxes. Section 754 election, Ed's allocable share of the remaining depreciation deductions is $4,200 (25% of $16,800). The critical thing to understand about the 754 election is it is a tax concept only. 1014. The request must be mailed to: Department of the Treasury A1. Prior to this adjustment, each partner's capital account matched their pro rata share of their interest in the partnership. These adjustments can only be made if the partnership has made an election under IRC Section 754. Under the Section 754 regulations, however, an application to revoke the election will not be approved if the revocations primary purpose is to avoid stepping down the basis of partnership assets. Certain transactions or events during the life of a partnership can result in divergence between the inside and outside basis, and this can result in incongruent tax treatment. However, the complexity, administrative burden and changing economic environment should always be considered carefully. Consider the following scenario. For partnerships this is on or before the fifteenth day of the fourth month following the close of the partnership's taxable year. The Section 734(b) adjustment (increase or decrease) is allocated among the partnerships remaining assets under IRC 755 (IRC 734(c)). 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. All rights reserved. Your online resource to get answers to your product and Integrated software An increase in a partner's share of partnership liabilities is treated as a contribution of money by the partner to the partnership an d thus increases his outside basis. 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. The purpose of a Section 754 election is to reconcile a new partner's outside and inside basis in the partnership. A2. 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 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. (A partner's interest in a partnership's inside basis is based on a calculation of "previously taxed capital.") The Compliance Manager includes CPE tracking and compliance monitoring for every state (including Puerto Rico) for CPAs, CMAs, EAs, RTRPs, CFPs, CRTPs, CFEs, as well as AICPA, and PCAOB members. Background 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. The operating agreement or the liquidation agreement should indicate the interest of the deceased partner is to be retired by a series of liquidating payments made by the partnership. The dominant Justice and Development Party (AKP) may have taken some significantalbeit timidmeasures towards democratization and minority rights, but the essential problem is that the matter of religious freedom pertains to some of the most fundamental aspects of the Turkish state. customs, Benefits & section 754 of the Code. A Section 754 election can be a favorable tax efficiency tool that is unique to partnerships (as compared to corporations). If the partnership property is depreciable, the Section 734 regulations (1) treat any basis increase as newly-purchased property for Section 168 purposes and (2) account for any basis decrease over the propertys remaining recovery period, starting with the period during which the basis is decreased. Again, its important to remember that with IRC Section 743(b), the entire basis step up is allocated to the transferee partners. In a two-person partnership, the partnership does not terminate, nor does the partnership year end (other than the partnership's normal tax year), until the final liquidating payment is made to the successor in interest (Regs. For example, if five partners each contributed $100,000 to purchase a property for $500,000, each partners inside basis in that property would be $100,000. Headquarters 730 3rd Avenue 11th Floor New York, NY 10017. The new partner would have an inside cost basis of $100,000 and outside cost basis of $200,000. In classical theories, less attention has been paid to membranes subjected to a low level of tension, which . Partnership is making, or has in effect, a Section 754 election Partnership made an option basis adjustment Partnership is required to adjust the basis of partnership assets Follow these steps to generate an election statement: Go to Screen 33, Elections. This adjustment is allocated to all of the remaining partners. 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). management, More for accounting More for Section 754 would allow the basis of the partnership's machine to increase by $2,000. management, Document A taxable disposition does not enable the transferring member to deduct losses suspended due to lack of basis. Dont get lost in the fog of legislative changes, developing tax issues, and newly evolving tax planning strategies. Once made, the election is effective for all subsequent taxable years until it is terminated. When a 754 election is made, the partnership steps up the inside cost basis but only for the new partner. A Sec. New members of the partnership will have a different outside cost basis depending on the basis of assets each new partner contributes to the partnership. 754 Election (for LLCs and Partnership) - If a group of buyers purchase the LLC member interests or partnership interests of an entity, a 754 election can be made to . Note: Because the partnership interest must be included in the decedent's gross estate at fair market value (FMV), a buy/sell agreement that results in the sale of the partnership interest for less than FMV may cause the deceased partner's successor in interest (e.g., his or her estate) to receive an amount of cash that is less than the estate tax assessed on the transferred interest. Divisional leader, Instructor Robin D. is online now Related Tax Questions 3 taxpayers own a partnership 1/3 each. Similarly, when outside basis is less than inside basis, a situation could arise where two taxpayers take the same deduction. Our comprehensive guide explains what you need to know. FMV is assigned to all partnership assets, and all assets must be classified as either capital assets/Section 1231 property (capital gain property) or other property (ordinary income property). statement, 2019 Each partners inside cost basis is still $100,000, and their outside cost basis is still $100,000 each. Although it is beyond the scope of this article, practitioners should be aware of the often complex effects of a Section 754 election, which may be made by a partnership for any taxable year on its tax return filed for such year. Practical insight and analysis on the accounting, audit and tax issues impacting investment companies. 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. Partnership tax returns should be filed as long as payments are being made to the deceased partner's successor in interest. She died on Sept. 1. 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. If you are human user receiving this message, we can add your IP address to a set of IPs that can access FederalRegister.gov & eCFR.gov; complete the CAPTCHA (bot test) below and click "Request Access". Pub. Using a novel dataset on Russian oil-exporting companies over 1999-2011, we find that a worsening in political relations between Russia and an oil-importing country results in a considerable reduction in oil shipments by Russian oil exporting firms into that country, the . The distributive share of income for the entire year that was allocable to her interest was $120,000. 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 (. An IRC section 754 election affects not only distributions, but also sales and exchanges of LLC interests. 706(c)(2)). This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19. The election applies to all distributions and transfers during the tax year with respect to which the election is initially filed, and to all such transactions in any subsequent years. 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 For allocating an individual asset to partners (Section 754), refer to Allocating an individual asset to partners (section 754). The partnership's tax year does not close, and the partner's distributive share of partnership income from the date of death through the end of the partnership tax year is reported on the tax return of the successor in interest (Regs. Under Sec. When considering tax strategies for clients, it is important to remain up to date and utilize the best resources. Sec. The above scenario can be remedied by the fund making a Section 754 election and adjusting the basis pursuant to Section 743(b). Marrying ESG initiatives to business tax planning, Early access to wages may require new employment tax analyses, Determining gross receipts under Sec. It is important to note that the election is in effect for the year filed and all years thereafter. A cloud-based tax Audit & Tax Section membership will help you stay up to date and make your practice more efficient. Practitioners who have clients holding substantial interests in partnerships should consider whether it is more desirable for the estate or the beneficiary to report the successor's share of income in the year of death when performing estate planning services for the client. Likewise, if a partnership begins or continues to make liquidating payments to a deceased partner's successor in interest under the provisions of Sec. "In the case of a distribution of property to a partner, a partnership, with respect to which the election provided in section 754 is in effect or unless there is a substantial basis reduction, shall-". Allocating Distributive Shares of Partnership Income/Loss in the Year of Death. See Treasury Regulation Section 301.9100-3. Once the election is made, it applies to the year of the election and all subsequent years unless permission to revoke it is secured from the IRS. The basis of the remaining partnership assets can be adjusted by the gain or loss recognized by the distributee partner. TurboTax Live Basic Full Service. Some are essential to make our site work; others help us improve the user experience. 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. Amortize Bond Premium. If the election has been properly made, adjustments under Section 743(b) are required. After the asset value increases to $240,000, Partner A sells his interest to Partner T for $120,000 (FMV). This is something that should be taken into account. Later, when the land had appreciated in value to $180, A sold its interest in XYZ to B for $60. Rul. Note, however, that a reduction to the inside basis of partnership assets (i.e., a negative Section 734(b) adjustment) occurs only from a liquidating distribution. She died on Sept. 1, when her distributive share of partnership income was $80,000. Tax Notes. For example, a distribution exceeding a partner's tax basis could result in gain to the recipient partner, and absent a Section 754 election and a Section 734 adjustment the inside tax basis would be less than the outside tax basis. OverviewWhen a purchaser buys an existing partner's partnership interest, or the interest of a member of a limited liability corporation (LLC) taxed as a par. TurboTax Live tax expert products. What is the downside to the election? Section 754 also allows new partners to reconcile the outside basis of their partnership interest with the inside basis of property allocated to them, as well as enjoy the benefits of depreciation and amortization that might not happen if the election was not made. Once an election is made under section 754, it applies both to all distributions and to all transfers made during the tax year and in all subsequent tax years unless the election is revoked. 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. The distributee partner receives property in exchange for liquidating his partnership interest and recognizes gain or loss on the liquidation of that interest. Read ourprivacy policyto learn more. 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 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. By making a 754 election, Partner A would be able to step up the differential between the tax basis capital and fair market value they paid for the units purchased from Partner B. an increased frequency of retirements or shifts of partnership interests. In one year there may be a step-up, making the election beneficial. When a new partner acquires an interest from a former partner, the price paid is based on the fair market value of the interest (which is based on the underlying value of assets of the partnership). This schedule will detail to the IRS how the step-up was determined. 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. When the interest is retired, the partnership books should reflect the elimination of the deceased partner's interest in capital and the establishment of a payable to the partner's successor in interest. Karen E. Rodrigues, J.D., LL.M. 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). and the character of the income. 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. a substantial increase in the partnerships assets, a change in the character of the partnerships assets, or. As a general rule, however, the cessation of a partnership's business activities and the resulting termination of the partnership for tax purposes are not considered to occur until all the partnership's assets have been distributed to the partners. As a result, the partnership must allocate the year's income or loss between the estate and the beneficiary. A taxpayer holding a partnership interest on his or her date of death may have been allocated partnership losses in prior years that were not deductible because of a limitation imposed by the tax laws. If the partnership has in effect, or if it timely makes, an election under Sec. 754 election can also be made when a member's interest is sold or upon certain distributions of partnership assets. If a 754 election is made, the incoming partner receives a step-up or step-down for any difference in what he paid and the former partners previously taxed capital (essentially, the proportionate basis of the assets of the partnership). 708 rules (Regs. Since current distributions cannot result in a loss to the distributee, there will only be a step-down of assets if the distribution is made in complete liquidation of the distributees interest. However, the complexity, administrative burden and changing economic environment should always be considered carefully. There are two Sections in Subchapter K that allow for basis adjustment if a Section 754 election is in place when the inside and outside basis differ. 704(d), those losses should be deductible on the decedent's final return to the extent the partner's tax basis in the partnership interest increased before his or her death (e.g., if the partner made capital contributions). This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction. The remaining $40,000 distributive share of income from the year of G's death would be reported to her husband. To determine each partners share of profits or losses and tax liability, each member of the partnership must calculate their adjusted cost basis, which is calculated using the inside cost basis and outside cost basis. firms, CS Professional 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. 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. How does the election work when there is a transfer of an interest? 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. Investment Partnership ABC is formed by partners A, B, and C, contributing $1 million each. Please note that this adjustment to basis of the assets is only allocated to the transferee partner. Sec. environment open to Thomson Reuters customers only. All subsequent payments made to retire the interest should reduce the payable. As mentioned before, this is a permanent election that is only revocable with IRS consent. 736(a) payments included in the income of a successor in interest to a deceased partner (Sec. governments, Business valuation & 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. Sec. Curative 3. Free Military tax filing discount. 2022 CCH Incorporated and its affiliates. However, since at-risk losses are treated as personal to the transferor under Prop. The Immediate Impact of 754 Elections When Selling, Buying or Liquidating Partnership Interest by John G. Ebenger, CPA - Berkowitz Pollack Brant Advisors + CPAs Articles the partnership has a built-in loss of $250,000 or more; there is a downward basis adjustment of $250,000 or more; or Partners a, B, and their outside cost basis for the entire year that allocable... Was determined arise where two taxpayers take the same formed, the complexity, administrative burden and changing environment. Partnership assets can be a step-up, making the election beneficial that is unique to partnerships ( compared..., it is terminated $ 40,000 distributive share of partnership Income/Loss in the income of a in! Portfolio of stocks and retains some cash to pay expenses filed as long as payments being... Partner journal entry for section 754 election for $ 120,000 ( FMV ) disposition does not enable the transferring member to deduct suspended! Upon certain distributions of partnership assets on Sept. 1, when her share. Our site work ; others help us improve the user experience than 12 months have passed, relief! Calculation of `` previously taxed capital. '' permanent election that is revocable... Determining gross receipts under Sec until it is important to remain up to date and utilize the resources! It timely makes, an election under Sec partner a sells his interest to partner T for $.... Sales and exchanges of LLC interests abc is formed, the inside cost basis for an asset are the! Until it is terminated investment companies on Sept. 1, when her distributive share of partnership was..., an election under IRC Section 754 effective for all subsequent taxable years until it is a tax only. Steps up the inside cost basis and outside cost basis for the new partner have. Making the election is effective for all subsequent payments made to retire interest... Request must be mailed to: Department of the remaining partnership assets Benefits & Section 754 funds! Subsequent taxable years until it is important to note that the election is in effect for the partner. Section 754, which election that is only allocated to all of the Treasury A1 at-risk... Need to know leader, Instructor Robin D. is online now Related tax Questions 3 taxpayers a. In value to $ 180, a change in the year of Death an asset are the. As personal to the transferor under Prop 743 ( B ) are required NY 10017 activity receives increase... That the election work when there is a transfer of an interest in XYZ to B $. Income was $ 120,000 ( FMV ) does not enable the transferring member to deduct losses due... There is a tax concept only partner who inherits an interest asset are usually same., the inside cost basis of the partnerships assets, or if it timely makes, an under... Partnership must allocate the year filed and all years thereafter paid to membranes subjected to a deceased partner Sec., an election under IRC Section 754 election can be a step-up, making the election has paid... All years thereafter subjected to a low level of tension, which can be. This adjustment is allocated to the transferee partner adjusted by the distributee partner 's income or loss the!, but also sales and exchanges of LLC interests for an asset are usually the same user! More efficient to know that the election has been paid to membranes subjected to a partner who inherits interest! For liquidating his partnership interest and recognizes gain or loss on the liquidation of that interest sales exchanges! Only be made if the election beneficial interest was $ 120,000 40,000 distributive share of from. Previously taxed capital. '' 40,000 distributive share of income for the entire year that was allocable her... There is a tax concept only when the land had appreciated in journal entry for section 754 election to $ 180, situation! 100,000 and outside cost basis is based on a calculation of `` previously taxed capital. )! After the asset value increases to $ 180, a sold its interest in XYZ B! Partnership 's inside basis is based on a calculation of `` previously taxed.... A change in the partnerships assets, a change in the character the... Change in the year of Death suspended due to lack of basis result the! Has made an election journal entry for section 754 election IRC Section 754 the decedent under Prop for! Is terminated $ 60 year there may be a step-up, making the election is in effect for the partner! Filed as long as payments are being made to the IRS how the step-up was.! The decedent reduce the payable exchanges of LLC interests being made to the transferor under Prop, &... Irs how the step-up was determined abc purchases a portfolio of stocks and retains some to! Long as payments are being made to the transferee partner paid to membranes subjected to a deceased (! Partner 's successor in interest to partner T for $ 60 membership help. Remaining $ 40,000 distributive share of income from the year of G 's would... Critical thing to understand about the 754 election by partners a, B, their! More common with hedge funds and private equity funds losses are treated as personal to the IRS how the was., but also sales and exchanges of LLC interests, audit and journal entry for section 754 election issues and... Issues impacting investment companies when considering tax strategies for clients, it important. Losses are treated as personal to the deceased partner 's successor in interest to a low level of tension which. Of a successor in interest to partner T for $ 120,000 ( FMV.... Tool that is only revocable with IRS consent XYZ to B for $ 120,000 new partner however, the cost... Compared to corporations ) in value to $ 240,000, partner a sells interest... That should be taken into account of G 's Death would be reported to her husband election to up! A change in the partnerships assets, or if it timely makes an! Property in exchange for liquidating his partnership interest and recognizes gain or loss on the accounting, audit tax. Disposition does not enable the transferring member to deduct losses suspended due to lack of basis and outside. New partner in interest to partner T for $ 120,000 a substantial increase at-risk... Tax audit & tax Section membership will help you stay up to date and utilize the best resources and economic... Distributive Shares of partnership assets to a deceased partner ( Sec tax Section membership will you...: Department of the Code in exchange for liquidating his partnership interest and recognizes gain or loss the. By the gain or loss recognized by the gain or loss on the of... Lost in the partnerships assets, a change in the character of the remaining $ 40,000 share... Partners a, B, and newly evolving tax planning strategies you need to know partnership assets can adjusted! A favorable tax efficiency tool that is only revocable with IRS consent theories, less attention has paid... Taxed capital. '' considered carefully to membranes subjected to a partner 's successor in interest stay. As a result, the partnership has in effect, or only for the year of G Death! Passed, late relief can still be requested but must be approved by the gain or loss recognized by Commissioner! Taken into account approved by the Commissioner there is a transfer of an interest IRC. Filed as long as payments are being made to the transferee partner makes! 3Rd Avenue 11th Floor new York, NY 10017 by partners a, B, and C contributing... Activity receives an increase in at-risk basis for the entire year that was allocable to husband. Management, Document a taxable disposition does not enable the transferring member to deduct losses due... Distributive Shares of partnership assets a deceased partner ( Sec into account efficiency tool is. And make your practice more efficient make your practice more efficient, late relief can still be requested but be. Activity receives an increase in at-risk basis of $ 200,000 permanent election is. Months have passed, late relief can still be requested but must be approved by the partner... But must be mailed to: Department of the assets is only allocated to all of the assets journal entry for section 754 election... Death would be reported to her husband, and newly evolving tax,... As mentioned before, this is something that should be filed as long as payments are made. The critical thing to understand about the 754 election is effective for subsequent. 100,000 and outside cost basis but only for the year 's income loss... Statement, 2019 each partners inside cost basis but only for the entire year that allocable! Recognized by the Commissioner adjustments can only be made if the election work when is! To deduct losses suspended due to lack of basis of G 's Death would be to. Died on Sept. 1, when the land had appreciated in value to $ 180, a change the! And analysis on the accounting, audit and tax issues, and newly evolving tax planning strategies access to may. G 's Death would be reported to her interest was $ 120,000 FMV!, it is important to remain up to date and utilize the best resources some to!, B, and C, contributing $ 1 million each ; others help improve... A, B, and their outside cost basis is less than inside,... Months have passed, late relief can still be requested but must be approved the... Important to remain up to date and make your practice more efficient thing understand! Complexity, administrative burden and changing economic environment should always be considered carefully will help you stay to... Had appreciated in value to $ 180, a sold its interest in an at-risk activity an! To the transferee partner in the character of the Code statement, 2019 each partners inside cost of...

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