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The Structure of Partnership Taxation
721 14 65 103 116
75la 20 145 146 149 154 155 1212
30 other sections not shown
751 property Accordingly aggregate inside basis aggregate outside basis allocated Applebaum apply assume at-risk Blackacre book/tax disparity capital account balances capital assets capital gain cash distributed Commissioner contributed property contributing partner corporation depreciation deduction disposition distributed property distributee-partner distributee-partner's economic effect entitled example fair market value gain or loss guaranteed payment holding period increase Internal Revenue Code inventory items investment Kinney limited partners limited partnership liquidating distribution loan McCauslen minimum gain nonrecourse debt nonrecourse deductions nonrecourse loan optional basis adjustment partner's interest partner's outside basis partner's share partnership agreement partnership assets partnership debt partnership distributes partnership income partnership interest partnership loss passive income petitioner prior profits interest provides purchase recognition of income recognized reduced regulations service partner share of partnership shareholder Stine Subchapter substantially appreciated supra tax consequences Tax Court tax-free taxable income taxation taxpayer tion transaction transfer Treas treated ULPA unrealized receivables Whiteacre