Add to ORKGI. Introduction II. Abandonments in General ... A. What Constitutes an Abandonment ... B. Timing the Abandonment Loss Deduction ... C. Income Tax Consequences ... 1. Prerequisites to the Abandonment Deduction ... 2. Income Tax Effect ... 3. Encumbered Property III. Abandoning a Partnership Interest ... A. What Constitutes the Abandonment of a Partnership Interest ... B. Tax Considerations ... 1. Overview ... 2. No Liabilities ... 3. Relief from Liabilities ... 4. Non-Sale Transfers—752(b) v. 752(d) ... 5. Worthlessness ( Practical Abandonment ) ... C. Impact of the Economic Recovery Tax Act IV. Conclusio
The preferred way for a withdrawing partner to leave a partnership is normally thought to be by way ...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
The primary purpose of this article is to encourage closely held business owners and their lawyers t...
As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies th...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
I. Introduction II. The Choice When a Partner Withdraws: Sale or Liquidation III. The Checkered Hist...
When a partner sells a partnership interest, the resulting gain or loss is treated as capital gain o...
When indebtedness of a partnership is discharged or cancelled, difficult conceptual and mechanical p...
This Note will discuss the tax consequences when a corporation liquidates and distributes its partne...
The fundamental question addressed in this thesis is: can the fall of the ordinary partnership be at...
This Article attempts to resolve one such issue: the tax consequences of property abandonments by th...
In 2004 Congress amended the code to prevent the use of a partnership contribution as a means of tra...
The author explains the operation of section 736 of the Internal Revenue Code, points out areas in w...
Income Tax Aspects of Liquidation of Partnership Interest of Retiring or Deceased Partne
If a person receives property as payment for services, whether for past or future services, the rece...
The preferred way for a withdrawing partner to leave a partnership is normally thought to be by way ...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
The primary purpose of this article is to encourage closely held business owners and their lawyers t...
As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies th...
In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships i...
I. Introduction II. The Choice When a Partner Withdraws: Sale or Liquidation III. The Checkered Hist...
When a partner sells a partnership interest, the resulting gain or loss is treated as capital gain o...
When indebtedness of a partnership is discharged or cancelled, difficult conceptual and mechanical p...
This Note will discuss the tax consequences when a corporation liquidates and distributes its partne...
The fundamental question addressed in this thesis is: can the fall of the ordinary partnership be at...
This Article attempts to resolve one such issue: the tax consequences of property abandonments by th...
In 2004 Congress amended the code to prevent the use of a partnership contribution as a means of tra...
The author explains the operation of section 736 of the Internal Revenue Code, points out areas in w...
Income Tax Aspects of Liquidation of Partnership Interest of Retiring or Deceased Partne
If a person receives property as payment for services, whether for past or future services, the rece...
The preferred way for a withdrawing partner to leave a partnership is normally thought to be by way ...
I. Introduction II. The Service Position on Partnership Valuation … A. The Asset Valuation Rule … 1....
The primary purpose of this article is to encourage closely held business owners and their lawyers t...