Joint Venture Partner Unable to Defer Gain Under Section 1033 When Property was Not Distributed Until One Day Prior to Closing of Condemnation Sale

Article Abstract:

The Internal Revenue Service ruled that a Joint Venture Partner was ineligible to defer gain under Section 1033 of the Internal Revenue Code because the substance of the transaction showed it was a sale of the property, not of tenancy-in-common interest for productive use or investment purposes.

Deferred income (Business), Deferred income

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Income That IRA Received From Limited Partnership Was UBTI

Article Abstract:

The Internal Revenue Service ruled that business income passing from the partnership through to the Individual Retirement Arrangement was unrelated business taxable income.

Information services, Tax exemption, Tax exemptions, Unrelated business income tax

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Net Operating loss Carryforwards Treated as Affected Items Subject to Computational Adjustment

Article Abstract:

The Court ruled that loss carryforwards were to be treated by the Internal Revenue Service as affected items at partnership level subject to computational adjustment.

Cases, Loss deductions

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