Can a residence owned by a partnership be treated as owned by the taxpayer for purposes of Sec 121 gain exclusion’s 2 out of 5-year ownership requirements? The IRS, originally in Letter Ruling 200004022, ruled that the time a home was owned by a partnership counted toward the 2 out of 5 years ownership requirement of Sec 121. Unfortunately, the IRS subsequently revoked that position with Letter Ruling 200119014 and currently a taxpayer is not treated as owning the home during the period it is held in a partnership.