If a person receives property as payment for services, whether for past or future services, the receipt typically constitutes gross income to the recipient. If a person performs services for a partnership or agrees to perform future services, and if the person receives a partnership interest as compensation for the past or future services, one might expect that receipt to cause the new partner to recognize gross income in an amount equal to the fair market value of the partnership interest. After all, if a corporation compensated someone for services rendered or to be rendered by transferring the corporation\u27s own stock to that person, the receipt of the stock would be included in the recipient\u27s gross income. One might question wheth...
It has become increasingly common for partnerships to issue options that give the holder the right t...
It has become increasingly common for partnerships to issue options that give the holder the right t...
For years tax advisors have assumed that the receipt of a profits interest in a partnership in retur...
If a person receives property as payment for services, whether for past or future services, the rece...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
For years tax advisors have assumed that the receipt of a profits interest in a partnership in retur...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
A recent Tax Court decision presents an opportunity to review the function of the partnership in the...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
A partnership pays no federal income tax. Instead, its income, deductions, and credits are allocated...
A partnership pays no federal income tax. Instead, its income, deductions, and credits are allocated...
Federal Income Tax - Diamond v. Commissioner (T.C. 1970). It is well established that an interest in...
Early cases involving the government\u27s invocation of section 2036(a) to combat the use of family ...
It has become increasingly common for partnerships to issue options that give the holder the right t...
It has become increasingly common for partnerships to issue options that give the holder the right t...
It has become increasingly common for partnerships to issue options that give the holder the right t...
For years tax advisors have assumed that the receipt of a profits interest in a partnership in retur...
If a person receives property as payment for services, whether for past or future services, the rece...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
For years tax advisors have assumed that the receipt of a profits interest in a partnership in retur...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
A recent Tax Court decision presents an opportunity to review the function of the partnership in the...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
A partnership pays no federal income tax. Instead, its income, deductions, and credits are allocated...
A partnership pays no federal income tax. Instead, its income, deductions, and credits are allocated...
Federal Income Tax - Diamond v. Commissioner (T.C. 1970). It is well established that an interest in...
Early cases involving the government\u27s invocation of section 2036(a) to combat the use of family ...
It has become increasingly common for partnerships to issue options that give the holder the right t...
It has become increasingly common for partnerships to issue options that give the holder the right t...
It has become increasingly common for partnerships to issue options that give the holder the right t...
For years tax advisors have assumed that the receipt of a profits interest in a partnership in retur...