i.e., an investment partnership). Under the Treasury Regulations, a transfer of property to an investment partnership occurs when: i. the transfer results, directly or indirectly, in diversification of the transferor’s interest; and ii. the transferee is (a) a regulated investment company, (b) a real estate investment trust, or (c) a corporation more than 80 percent of the value of whose assets (excluding cash and nonconvertible debt obligations from consideration) are held for investment and are readily marketable stocks or securities, or interests in regulated investment companies or real estate investment trusts. Thus, a transfer to an investment partnership only occurs when