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Table of Contents vii
Tax Treatment of the S Corporation
32 other sections not shown
50 percent 5th Cir Accordingly acquired adjusted basis AFTR2d allocation amount audit capital account capital contributions capital gain cash contributed property corporation election corporation status corporation's debt decedent decedent's December 31 deduction deficiency distributive share entitled exchange expenses fees filed FPAA guaranteed payments Held included individual investment investors IRS argued IRS determined IRS disallowed IRS found IRS took IRS's joint venture lease liabilities limited partners limited partnership interest liquidation loan nonrecourse nonrecourse debt operating ordinary income ownership P-H Memo paid parties partner's interest partnership agreement partnership income partnership losses partnership return percent interest prior Priv profits promissory note pursuant real estate Regulation Section reported result Revenue Ruling share of partnership shareholders sold Subchapter subsidiary tax avoidance Tax Court tax return Taxpayer argued Taxpayer claimed terminated trade or business transaction transfer treated trust unrealized receivables USTC wife