| 19(1) | File No. 5-9076 |
| R. Albert | |
| (613) 957-2098 |
November 20, 1989
Dear Sirs:
Re: Subsection 97(2) of the Income Tax Act (the "Act")
We are writing in reply to your letter of November 20, 1989 wherein you requested written confirmation of the availability of a rollover of inventory which is real property into a partnership. Your query results from the apparent exclusion of this type of property from the Form T2059 "Election on Disposition of Property by a Taxpayer to a Canadian Partnership".
We confirm the availability of a rollover of inventory which is real property into a partnership under the provisions of subsection 97(2) of the Act.
We trust that these comments will be of assistance.
Yours truly,
B.W. Dath DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch