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PARTI TAXATION OF PARTNERS
Formation of the Partnership
Operation of the Partnership
12 other sections not shown
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adjusted amount apply built-in gain capital account balances Capital Asset capital gains capital interest carryover paragraph cash CBIT change the citation citation to Regulations citation to Temporary Commissioner contributed property contributing partner corporate characteristic Cum.Bull deduction delete the citation depreciation determined discharge of indebtedness disguised sale distributee partner distribution dividend economic risk fair market value free transferability gain or loss guaranteed payment indebtedness income Internal Revenue Service limited liability company limited partners limited partnership liquidation LLC agreement member-managers nonrecourse debt obligation ordinary income partner's share partnership capital partnership interest partnership profits percent profits interest Proposed Regulations receipt recognized remedial allocation result Rev.Proc Rev.Rul Revenue Procedure risk of loss second full paragraph section 721 section 83 service partner share of partnership shareholders Tax Court taxable income taxation taxpayer Temporary Regulations third full paragraph tion transaction transferability of interests treated unrealized receivables video arcade