(a) Sale or exchange of certain distributed property. — The gain or loss on the disposition by a partner of unrealized receivables or inventory items, as they are defined in this part, which are distributed by a special partnership shall be considered as ordinary. This subsection shall not apply to the sale or exchange of inventory items carried out after five (5) years from the date of distribution.(b) Holding period for distributed property. — In determining the period for which a partner has held distributed property, other than for purposes of subsection (a), the provisions of § 30141(i) of this title shall apply.(c) Unrealized receivables. — For purposes of this subchapter, the term 'unrealized receivables' includes, to the extent that these are not previously includible in income of the special partnership, any right to payment for:(1) Goods delivered, or to be delivered, to the extent that the proceeds therefrom would be treated as ordinary income, or(2) services rendered, or to be rendered.(d) Inventory items. — For purposes of this subchapter, the term 'inventory items' shall mean:(1) Property of the special partnership of the type described in § 30141(a)(1)(A) of this

to be rendered.(d) Inventory items. — For purposes of this subchapter, the term 'inventory items' shall mean:(1) Property of the special partnership of the type described in § 30141(a)(1)(A) of this title;(2) any other property of the special partnership which, if sold or exchanged by the partnership, would not be considered as a capital asset or property of the type described in § 30141(i) of this title, and(3) any other property held by the partnership which, if held by the partner, would be considered property of the type described in clause (1) or (2) above. History —Jan. 31, 2011, No. 1, § 1114.20, retroactive to Jan. 1, 2011.