Federal Income Tax Project: Tentative Draft, Issues 8-10The Institute, 1982 - Corporations |
Contents
PART Q PARTNERSHIP LIABILITIES | 1 |
COMMENTS | 6 |
Allocating Liabilities Among General and Limited Partners | 27 |
41 other sections not shown
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Common terms and phrases
accounting activities allocated American Law Institute apply appropriate basis capital gain treatment capital interest cash Code provisions Comment on Example considered contributed property corporation corpus cotton creator creator's spouse deduction depreciation determining distributable net income election Estate situation Example 13 extent fair market value foreign persons gross income guaranteed payment Herbert Wechsler included income tax incurred individual intangible interest in Partnership Internal Revenue Code Internal Revenue Service inventory investment issue land liabilities limited partner liquidation loan motive nonrecourse nonrecourse debt ordinary income Otey partners in Partnership Partnership ABC partnership agreement partnership interest partnership level pass-through approach present law problems profits interest Proposal provides purchase purpose received regulations relevant replacement property Reporters result sale to customers Section sells separate share of partnership shareholder sold Subchapter taxable taxation taxpayer tier partnership tion transaction treated trust beneficiary trust income trust property U.S.-source United Washington York