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lnitial Pitfalls Associated with
Partnership Allocations DONALD J Wemman
The Corporate General Partner
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adjusted basis agreement alimony amount Annual Tax Conference annuity apply basis adjustment beneﬁciary capital gain Code Cong contributed property contribution death decedent deduction deﬁned deﬁnition depreciation determined election estate tax excess exchange expenses extent fair market value Federal ﬁnancing ﬁrst ﬁscal gross estate income tax installment sale Internal Revenue Service investment investors itemized deductions lease like-kind limited partners limited partnership ment minimum tax mortgage nership non-recourse ordinary income partnership interest partnership property payments percent period prior problems proﬁts provides purchase qualiﬁed real estate real property recapture received recognized redemption reﬂect regulations respect result Revenue Ruling risk section 303 Service Sess share shareholders signiﬁcant simpliﬁcation special allocation speciﬁc Subchapter S corporation supra tax beneﬁt tax consequences Tax Court tax laws tax preference Tax Reform Act tax shelter taxable income Taxation taxpayer tion transaction transfer Treas trust