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An Overview of Subchapter
Acquisitions of Partnership Interests
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2d Sess 5th Cir activity adjusted basis afTd aggregate allocation amount apply cash Commissioner computing Cong contributed property depreciation determined distributive share economic effect economic risk election entity example exchange fair market value filed FPAA gain or loss gross income increase infra investment limited partner limited partnership liquidation loan minimum gain chargeback nership nonrecourse debt nonrecourse deductions nonrecourse liability nonrecourse loan obligation ordinary income partner's interest partner's share partnership agreement partnership income partnership interest partnership items partnership liabilities partnership minimum gain partnership property partnership taxable payment portion prior Priv profits interest Prop provides qualified real property recapture respect result Revenue Procedure Revenue Ruling risk of loss Section Service share of partnership statute Subchapter substantial Tax Court Tax Matters Partner tax purposes tax-exempt taxable income taxpayer Temp Temporary Regulations termination tion trade or business transaction transfer treated ULPA