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Full-Text Articles in Law
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 2), John W. Lee
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 2), John W. Lee
Faculty Publications
In this article, Professor Lee charts two alternative methods for implementing an aggregate solution to the problem of partnership profits share for services. The functional, or judicial, method is to handle (1) the exchange of partner-capacity services for a profit share subject to the risk f the venture with the Culbertson "common law relation of partnership," nonrealization event doctrine, implicitly contemplated by the 1984 legislative history to section 707(a)(2), (2) the classic Diamond transitory partner with a substance-over-form rule or step-transaction rule, and (3) a sale of the partnership interest in circumstances that would result in ordinary income in a …
Recent Developments In The Income Taxation Of Individuals, Trusts, Estates And Partnerships, Meade Emory
Recent Developments In The Income Taxation Of Individuals, Trusts, Estates And Partnerships, Meade Emory
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments - Taxation Of Individuals, Partnerships, Estates And Trusts And Exempt Organizations, Meade Emory
Recent Developments - Taxation Of Individuals, Partnerships, Estates And Trusts And Exempt Organizations, Meade Emory
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments In The Income Taxation Of Individuals, Partnerships, Estates, & Trusts, Meade Emory
Recent Developments In The Income Taxation Of Individuals, Partnerships, Estates, & Trusts, Meade Emory
William & Mary Annual Tax Conference
No abstract provided.
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Faculty Publications
No abstract provided.
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
Faculty Publications
No abstract provided.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Faculty Publications
In the recent Rodman case, the Tax Court has held that a partner newly admitted near year-end must report his share of the full year's partnership profits. Messrs. Lee and Parker analyze the status of retroactive partnership allocations in view of Rodman, the first decision to expressly sanction retroactive allocations of income (and implicitly of losses) to new partners, and reallocations under Section 704.