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David T. Leibell and Daniel L. Daniels, partners at Wiggin and Dana LLP, in Stamford, Conn., report: Private Letter Ruling 200734023, issued Aug. 24, 2007, shows how the Internal Revenue Code Section 4941 self-dealing rules apply in a situation involving the liquidation of partnerships in which a private foundation held an interest. The taxpayer sought and received a ruling that the liquidation of

David T. Leibell and Daniel L. Daniels, partners at Wiggin and Dana LLP, in Stamford, Conn., report:

Private Letter Ruling 200734023, issued Aug. 24, 2007, shows how the Internal Revenue Code Section 4941 self-dealing rules apply in a situation involving the liquidation of partnerships in which a private foundation held an interest. The taxpayer sought — and received — a ruling that the liquidation of the three limited partnerships and the pro rata distribution of assets to the

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