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Recent cases and rulings

Article Abstract:

Several important cases and rulings involving partnership interests are discussed. The cases are the treatment of loss in withdrawal from partnership interest, the power of a general partner in prolonging tax assessment periods, the non-inclusion of gifts of limited partnership interests in an estate, the non-corporate status of partnerships whose securities are not traded and the obligation to report the nomination of partnership interests.

Author: Losey, F. Richard
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1992

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Recent cases and rulings

Article Abstract:

The Tax Court rejected a taxpayer's arguments that he was at risk with respect to partnership debt obligations since efforts have been made to guarantee that there was no realistic possibility that the taxpayer would eventually be liable to make payments. In another case, the court ruled that the transfer of the limited partnership interests to a partner's trust by reason of one partner's death did not lead to a credit recapture.

Author: Losey, F. Richard
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1998

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Tax Court Lacked Jurisdiction in Affected Items Proceeding to Redetermine Deficiencies Resulting From Partnership Adjustments

Article Abstract:

Despite the IRS' failure to issue a notice of deficiency to the partners for the partnership items prior to assessment thereof, the court held notice on the partnership-level proceeding was sufficient to bind the partners.

Author: Losey, F. Richard
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1997
United States, Laws, regulations and rules, Notice (Law), United States. Internal Revenue Service

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Subjects list: Cases, Partnership, Partnerships
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