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751 property adjusted basis allocated amount at risk apply at-risk rules basis adjustment basis of partnership capital contribution capital gain cash CCH Dec Code Sec contributed property corporation decrease deemed depreciation determined disposition distributee partner distributive share entity Example expenses fair market value gain or loss gross income guaranteed payments increase interest in partnership inventory items investment Joint Venture limited partner limited partnership loan material participation minimum gain Model Partnership Agreements nership nonrecourse debt nonrecourse deductions nonrecourse liability nonrecourse loan obligation ordinary income parties partner's basis partner's interest partner's share partnership assets partnership interest partnership liabilities partnership property Partnership Tax Reports passive activity passive income percent person proposed regulations pursuant real property recapture recognized respect sale or exchange share of partnership ship substantially appreciated Tax Reform Act taxpayer TC Memo Temp tion trade or business transaction treated unrealized receivables USTC