Journal of Partnership Taxation 1992 |
Title | Subject | Authors |
Abandonment of partnership interest allowed as ground for loss deduction. (Echols versus Comm'r) (Recent Cases and Rulings) | Business | Losey, F. Richard |
Accounting issues: failure to pay the piper can accelerate a requirement to pay Uncle Sam. (failure of a partner to restore a deficit capital account) | Business | Carman, William T., Dance, Glenn E. |
Accounting issues. (Tax Equity and Fiscal Responsibility Act of 1982, Section 706(d)(2)) | Business | Gaughan, Robert J., Jr., Carman, William T. |
Admission of a partner to a service partnership: resolving the tax problems. | Business | Berman, Steven P. |
Basis of a transferred partnership interest: a will-o'-the wisp created by the new debt allocation regulations. (Accounting Issues) | Business | Carman, William T., O'Neil, Paul A. |
Canadian limited partner had U.S. "permanent establishment." (Unger versus Comm'r) (Recent Cases and Rulings) | Business | Losey, F. Richard |
Consequences of preferred return provisions in a partnership agreement. | Business | Schoenbrun, Gary L. |
Constructive partnership terminations and the depreciation antichurning rules. | Business | Boyd, James H., O'dell, Michael A. |
Disallowance of losses and deferral of deductions in partnership transactions. | Business | Wisialowski, Thomas S., Schaaf, Douglas A. |
Eighth Circuit's decision in Campbell clarifies the limited scope of Diamond. (Campbell v. Comm'r; Diamond v. Comm'r; taxation of partnership profits interest received for services) | Business | Ruffer, Richard A., Jr. |
Estate planning. (Beaty v. United States, a case of estate tax lien on partnership interest) | Business | Tousey, Clay B., Jr., Wallis, Donald W. |
Evaluating the many options that exist for restructuring partnership debt. | Business | Grudzinski, Chester W., Jr. |
Final regulations concerning liabilities join substantial economic effect rules. | Business | Hamill, Susan Pace |
FPAA did not preclude enforcement of IRS summonses. (financial partnership administrative adjustment) (Recent Cases and Rulings) | Business | Losey, F. Richard |
How to exploit the interaction between Subchapter K and the alternative minimum tax. | Business | White, Stephen J., Pratt, James W. |
Information return preparer for limited partners is liable for penalties for negligent preparation of the partners' returns. (Recent Cases and Rulings) | Business | Losey, F. Richard |
International developments. (Internal Revenue Service regulations on foreign partners) | Business | Bell, William W., Shoemaker, David B. |
New estate freeze rules: practical issues for gift leveraging. (part 2) | Business | Evaul, David, Wallace, Todd, Stolbach, Gary |
New estate freeze rules: tax and business planning impact on partnerships. | Business | Evaul, David, Wallace, Todd, Stolbach, Gary |
New proposed regulations substantially narrow the definition of royalties for purposes of passive investment income under Subchapter S. (S Corporations) | Business | August, Jerald David, Schepps, Mitchell D. |
Numerous options exist for specially allocating depletion, but which is best? (accounting for partnership investments in oil and gas properties) | Business | Robison, Jack, Mark, Richard S. |
Partnership classification: recent developments. (Washington Tax Watch) | Business | Montgomery, Steve, Hanley, Ed |
Partnership return did not affect partner's statute of limitations. (Siben versus Comm'r; Stahl versus Comm'r) (Recent Cases and Rulings) | Business | Losey, F. Richard |
Profits interest in partnership has only speculative value - Campbell reversed. (Campbell versus Comm'r) (Recent Cases and Rulings) | Business | Losey, F. Richard |
Proposed regulations on disguised sales provide help but may be too stringent. | Business | Tobler, Kim E., Bobrow, Richard S. |
Recent cases and rulings. (partnership taxation) | Business | Losey, F. Richard |
Sale of land by partnership to related corporation yielded capital gain. (Recent Cases and Rulings) | Business | Losey, F. Richard |
S corporations. (subchapter s corporations) | Business | Comiter, Richard B., Wolf, Robert M. |
Selling a partnership interest after an election out of subchapter K. | Business | Baer, Noah S. |
Statute of limitations is affirmative defense in partnership proceeding. (Recent Cases and Rulings) | Business | Losey, F. Richard |
Tax-oriented investments. | Business | Brenman, Lawrence H. |
Tax-oriented investments; an exit strategy for partners: abandonment of partnership interests. | Business | Brenman, Lawrence H. |
Texas limited liability companies treated as partnerships. (Recent Cases and Rulings) | Business | Losey, F. Richard |
Use of buy/sell agreements and life insurance in a partnership. (Estate Planning) | Business | Tousey, Clay B., Jr., Wallis, Donald W. |
Washington tax watch: Treasury revises liability allocation rules. (Department of the Treasury) | Business | Cullins, John W., Miller, Nancy L., Montgomery, Steve |
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