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Table of Treasury Regulations
Table of Miscellaneous Rulings
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2d Sess 754 election accounts receivable adjusted basis apply capital account capital asset capital gain Commissioner Cong considered contributed property corporation decedent decedent's deductions depreciation determined dollars entity example extent facts fair market value Federal income tax gain or loss goodwill guaranteed payments income or loss inside basis Internal Revenue Code Internal Revenue Service inventory items investment investors issue joint venture lawyer limited partners limited partnership liquidation loan ment nership nonrecourse debt ordinary income parties partner's interest partner's outside basis partner's share partnership agreement partnership assets partnership income partnership interest Partnership Taxation percent petitioner problem Professor of Law profits provides purchase recognized regulations respect result retiring partner Rev.Rul Revenue Ruling S.Ct sale or exchange Section 751 sells share of partnership shareholders ship special allocation Subchapter substantial supra tax benefits tax consequences Tax Court tax purposes taxable income taxpayer tion transaction transfer treated treatment unrealized receivables