Law Commons^™

Receipt Of A Profits Interest In A Partnership As A Taxable Event After Campbell And Mark Iv, The, Mark Winfield Brennan

Missouri Law Review

For years tax advisors have assumed that the receipt of a profits interest in a partnership in return for services is not a taxable event; instead, the stream of income derived from the profits interest is taxable as received. The only authority to the contrary was considered an "aberration" and nearly completely disregarded A tax court memorandum decision, Campbell v. Commissioner, appeared to change the way in which tax advisors must approach the topic. Mark IV Productions, Inc. v. Commissioner, a memorandum decision handed down only seven months after Campbell, however, abruptly altered once again the tax court's position on …