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On October 26, 2021, the Tax Court issued a memorandum decision (1) on the 2009 acquisition of the Chicago Cubs baseball team structured as a leveraged partnership transaction. As part [...]

The early years of businesses often lend themselves well to the flow-through characteristics of partnerships and S corporations. However, taxpayers should understand the limitations and restrictions with respect specifically to [...]

When an owner of a passthrough entity dies, certain tax implications may arise on both the individual and entity level. This article examines the various federal income tax issues to [...]

Introduction (1) In private equity acquisitions and dispositions of portfolio companies, fund manager "stakes" deals, and other business transactions involving the transfer of partnership interests or distributions from partnerships, it [...]

Introduction Partnerships and S corporations are the two most popular forms of business organization. The most recent SOI data reports just under five million Form 1120S filings and just under [...]

I. Introduction Congress has supported Code Sec. 170(h), which allows for conservation easement donations and related tax deductions, for decades. In upholding and expanding the benefits of this tax provision [...]

If a delinquent return is submitted to and received by an authorized IRS official requesting it, the return need not be sent to an IRS service center to be considered [...]

For purposes of the Sec. 6751(b) supervisory approval requirement for penalties, the immediate supervisor who must approve the penalties is the person who directly supervises the work in an examination [...]

The reporting rules for partnerships regarding basis adjustments under Sec. 743(b) have been in place for over 20 years, but, often, not all the pieces of the rules are stuck [...]

Introduction Code Sec. 1014(a)(1) provides a general rule that the tax basis of property acquired from a decedent is the fair market value (FMV) of that property determined at the [...]

Phillip Gall examines the history of the Code Sec. 708 continuation rules and analyzes when a partnership should be considered a continuation of an existing partnership in a variety of [...]

Since the issuance of proposed regulations a couple of years ago, practitioners in the partnership and real estate area have been anticipating the demise of common transactions that utilize debt [...]

Generally when a successful business is acquired, whether by an asset acquisition or an equity acquisition, the assets will include both tangible and intangible property. When an entity conducting a [...]

5. Harding (1953) C.B. Harding, like Flood and Cluett, is another pre-1954 Code case involving a bad debt deduction. As discussed below, its principles also have been applied in cases [...]

IV. (Non?-)Attribution of a Partnership's Motive, Intent and Purpose to Its Partners We now move away from partnership-to-partner (non?-)attribution involving the related (if not overlapping) areas of activities and of [...]

I. Introduction A. Scope of This Article This article focuses on four questions: 1. Should the (1) activities, (2) trade or business status, (3) motive, (4) intent, or (5) purpose [...]

This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships. The discussion covers developments in income allocations, disguised sales, partnership distributions, terminations, and basis [...]

Introduction Taxpayers generally welcomed the issuance of Notice 2007-13 ("Notice"), which announced future regulations that will fundamentally change how the substantial assistance rules under Code Sec. 954(e) and Reg. § [...]

Introduction From Australian entrepreneurs providing capital to U.S. advertising agencies to Zaire businessmen serving as a source of funding for zinc exploration, the daily financial news continues to make us [...]

On Jan. 30, 2014, the Treasury Department issued new proposed regulations (REG-119305-11) intended to clarify the disguised-sale rules under Sec. 707 and the allocation of partnership liabilities under Sec. 752. [...]

EXECUTIVE SUMMARY * More and more businesses, including partnerships, are awarding equity interests to valued employees to keep them. * Partnerships often are unaware that even a small equity interest [...]