Selling a partnership interest works like selling any asset, with two extras. The amount realized includes any partnership debt the seller is relieved of, and any portion of the gain tied to unrealized receivables or depreciation recapture potential comes out as ordinary income while the remainder stays capital. The capital remainder is sorted by holding period: 1 year or less is short term and longer than 1 year is long term. A publicly traded partnership interest adds special limits: each PTP's passive limits apply separately, so its losses offset only the same PTP's passive income and the excess carries forward. Selling the entire interest to an unrelated person in a fully taxable deal lifts the limit and frees the suspended losses. If the PTP activity ends the year with an overall gain, the net gain portion (total gain minus total losses) is nonpassive income. The special allowance for rental real estate activities doesn’t apply to PALs from a PTP.
Worked example
A partner sells a PTP interest for $28,000 cash plus $5,000 of liability relief, realizing $33,000 against a $27,000 adjusted basis: a $6,000 gain. Her $4,000 share of depreciation recapture potential is ordinary income and the other $2,000 is capital gain. She also carried a $9,000 suspended PTP loss; because she sold her entire interest to an unrelated buyer in a fully taxable sale, the $9,000 is freed this year.