(A) In the case of any realty held by a partnership, no levy shall be imposed pursuant to this subchapter by reason of any transfer of an interest in a partnership or otherwise if:
(1) That partnership (or another partnership) is considered a continuing partnership within the meaning of § 708 of the Internal Revenue Code of 1954; and,
(2) The continuing partnership continues to hold the realty concerned.
(B) If there is a termination of any partnership within the meaning of § 708 of the Internal Revenue Code of 1954 for purposes of this subchapter, the partnership shall be treated as having executed an instrument whereby there was conveyed, for fair market value (exclusive of the value of any lien or encumbrance remaining thereon) all realty held by the partnership at the time of the termination.
(C) Not more than one tax shall be imposed pursuant to this subchapter by reason of a termination described in division (B) above and any transfer pursuant thereto, with respect to the realty held by the partnership at the time of the termination.
('61 Code, § 20.31) (Ord. 500, passed - - )