All Section 216 co-ops held free of Section 277 but subject to Subchapter T deduction limits

Article Abstract:

The Tax Court's 1996 Thwaites Terrace House decision held that all IRC Section 216 housing cooperatives are not subject to Section 277 deduction limits but are subject to those in Subchapter T. The court's decision regarding Subchapter T's universal applicability was based on its previous rulings, including its 1995 Trump Village and 1996 Park Place rulings, and on the petitioner's ability to meet the court's three-pronged test for defining a S. 216 co-op.

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Further thoughts on the proposed revision of Section 216's 80/20 test

Article Abstract:

Retired IRS official Emil O. Muhs, Jr., in a series of correspondances, states that aspects of the proposed revision of IRC Section 216(b)(1)(D)'s 80/20 test are problematic. The proposed revision is designed to ease qualification problems for cooperative housing corporations concerning default units. Issues concerning capital contributions, concession income, and discharge of indebtedness are also discussed.

Beliefs, opinions and attitudes, Muhs, Emil O., Jr.

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