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The Tax Character of Partnerships
b Impact on the Partnership
28 other sections not shown
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acquiring corporation adjusted basis amount apply capital account capital gain cash class of stock Commissioner common stock Congress contributed property contribution Corp corporation's debt deduction depreciation determined distributive share dividend earnings and profits economic effect election entity equity exchange fact fair market value federal income tax gain or loss goodwill guaranteed payment individual inside basis Internal Revenue Code investment issue limited liability limited liability company limited partners limited partnership liquidation merger Neubecker nonrecourse nonrecourse debt operating ordinary income ownership paid parties partner's interest partnership agreement partnership income partnership interest percent petitioner petitioner's preferred stock PROBLEM profits interest purchase recognized redemption regulations remaining reorganization rules sell shareholders Subchapter subsidiary substantial supra note target target corporation Tax Court tax return taxable income taxation taxpayer termination transaction transfer transferor Treasury treated unrealized receivables X Corp