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In Rev. Rul. 93-80, the IRS has ruled that a loss that is incurred on the abandonment or worthlessness of a partnership interest is an ordinary loss unless sale or exchange treatment applies. If there is an actual or deemed distribution to the partner, or if the transaction is otherwise in substance a sale or exchange, the partner's loss is capital (except as provided in Section 751(b)). Even a de minimis actual or deemed distribution makes an entire loss a capital loss.
