9781566627993

Partnership Income Taxation

by
  • ISBN13:

    9781566627993

  • ISBN10:

    1566627990

  • Edition: 3rd
  • Format: Paperback
  • Copyright: 1999-09-01
  • Publisher: West Group
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Table of Contents

Preface v
The Pass-Through Principle of Partnership Taxation
1(12)
Introduction
1(2)
Illustration
3(2)
The Tax Basis of Partnership Interests and Partnership Property
5(2)
The Timing of Partnership Income
7(1)
The Duration of A Partnership
8(1)
Partners As Self-Employed Taxpayers
9(1)
The ``Anti-Abuse'' Regulations
10(2)
Comparison with Sub S
12(1)
An Introduction to Partnership Debt
13(18)
The Effects of Debt Transactions upon Partners
13(2)
Determining the Partners' Shares of Partnership Debt
15(9)
Some Aspects of Debt
15(2)
What Is A Partnership Debt?
17(1)
Determining A Partner's Share of Debt under the Regulations
18(1)
Nonrecourse Debt
18(3)
Recourse Debt
21(2)
``Anti-Abuse rules'' and the Allocation of Debt
23(1)
Limits On the Deductibility of Partnership Losses
24(5)
Section 704(D)
25(1)
The At-Risk Rules of Section 465
26(1)
The Passive-Loss Rules of Section 469
27(2)
Comparison with Subchapters
29(2)
Contributions to Partnerships
31(24)
Contributions of Property
31(7)
The Statutory Pattern
31(1)
Problems Involving Liabilities
32(4)
Depreciation Recapture
36(1)
Character Issues: Section 724
37(1)
Contributions of Services
38(9)
Receipt of an Interest in Partnership Capital
39(3)
Receipt of an Interest in Partnership Profits
42(5)
Contributions Distinguished From Other Transactions
47(5)
Contribution vs. Sale to Partnership
48(3)
Contribution vs. Sale or Exchange between Partners
51(1)
Comparison with Subs
52(3)
Allocations of Partnership Income, Deductions, and Credits: An Introduction
55(38)
An Overview of the Code and Regulations
55(1)
The ``Substantial Economic Effect'' Test
56(20)
Introduction
56(1)
Capital Accounts
57(4)
The ``Substantial Economic Effect'' Regulations
61(1)
Determining ``Economic Effect'' When Capital-Account Deficits Need Not Be Repaid
62(3)
The ``Substantiality'' Rules
65(4)
Some Special Problems
69(1)
Depreciation
69(3)
Deductions Attributable to Nonrecourse Debt
72(4)
Contributed Property: Section 704(C)
76(16)
Allocations of Gain or Loss
76(4)
Allocations of Depreciation
80(1)
The Traditional Method
80(2)
The Traditional Method with Curative Allocations
82(3)
The Traditional Method with Remedial Allocations
85(3)
``Reverse § 704(c) Allocations'' under Section 704(b)
88(1)
Distributions of Section 704(c) Property
89(1)
Distributions of Property to a Partner Who Has Contributed Section 704(c) Assets
90(2)
Allocating Credits
92(1)
Comparison with Subs
92(1)
Partnership Allocations: Assignment-of Income Problems
93(8)
Family Partnerships
93(3)
Last-Minute Partners: Section 706(D)
96(1)
Assignments of Income Not Dealt With By Specific Code Provisions: the Anti-Abuse Regulations
96(4)
Comparison with Subs
100(1)
Transactions between Partnerships and Their Partners
101(12)
Income-Related Payments: Distributive Shares and Section 707(a) Payments
103(3)
Fixed Payments: Guaranteed Payments and Section 707(a) Payments
106(1)
Determining Whether A ``Partner Capacity'' Payment Is A Distributive Share or a Guaranteed Payment
107(3)
Minimum Payments
107(3)
Payments Measured by a Partnership's Gross Income
110(1)
Some Other Aspects of Transactions Between Partners And Partnerships
110(1)
Comparison with Subchapters
111(2)
Sales of Partnership Interests
113(20)
Taxation of the Seller
113(6)
The Seller's Amount Realized
113(1)
Section 751 (a)
114(5)
The Buyer's outside and Inside Bases
119(10)
The Buyer's Outside Basis
119(1)
Inside Basis Adjustments under Section 743(b)
119(1)
Determining the Transferee's Share of Inside Basis
120(2)
Allocating § 743(b) Adjustments to Particular Assets
122(4)
Using the § 743(b) Adjustment
126(1)
The Section 754 Election
127(1)
Basis Adjustments under Section 732(d)
128(1)
Collateral Effects of A Sale of A Partnership Interest
129(2)
Comparison with Subs
131(2)
Calculating Gain on the Sale of Stock
131(1)
Character of Gain and Inside Basis Adjustments upon Transfers of Interests
131(1)
Termination by Sale
132(1)
Partnership Distributions: an Introduction
133(16)
The General Principle of Nonrecognition
134(5)
Cases in Which Gain or Loss is Recognized
139(6)
Gain Recognition
139(2)
Liquidating Distributions on Which Loss Is Recognized
141(1)
``De Minimis'' Distributions of Property
142(1)
Distributions of Section 704(c) Property
143(1)
Distributions Taxed under Section 737
144(1)
Distributions and the Anti-Abuse Regulations
145(1)
Tax Treatment of the Partnership
146(1)
Comparison with Subchapters
146(3)
Distributions Subject to Section 751(b)
149(16)
Liquidating Distributions of Assets Other Than Section 751 Assets
152(4)
Liquidating Distributions of Section 751 Property
156(3)
Section 751 (a) and Current Distributions
159(2)
The Scope of Section 751 (a): An Example
161(2)
Comparison with Subchapters
163(2)
Payments to Retiring Partners: Section 736 and Related Problems
165(16)
Introduction
165(4)
Payments ``for Property'' and Other Payments
167(1)
Payments by Service Partnerships to General Partners
167(2)
How Section 736 Payments Are Taxed
169(2)
Examples
171(2)
Some Complications
173(3)
The Relationship between Section 736 and Section 751 (b)
173(2)
A Refinement in the Definition of Section 736(a) Payments
175(1)
Liquidation of an Entire Partnership
175(1)
Sales and Retirement Payments Distinguished
176(3)
Problems of ``Form'' and ``Substance''
179(1)
Comparison with Subchapters
180(1)
Basis Adjustments under Section 734
181(10)
Adjustments Under Section 734
182(5)
Distributions That Change the Basis of Property
182(1)
Distributions on Which Gain or Loss Is Recognized
183(3)
Allocating the Adjustment to Particular Asset
186(1)
Section 734 and the Anti-Abuse Regulations
187(2)
Comparison with Subchapters
189(2)
The Death of a Partner
191(8)
Income in Respect of a Deceased Partner
191(5)
Introduction
191(1)
The Basis of an Inherited Partnership Interest
192(4)
Closing the Partnership's Taxable Year upon the Death of a Partner
196(1)
Sale or Liquidation of a Deceased Partner's Interest
197(1)
Comparison with Subchapters
197(2)
What Is a Partnership?
199(12)
Partnership vs. Cost-Sharing and Employment Arrangements
200(1)
Partnership vs. Co-Ownership Of Property
201(3)
Partnership vs. Corporation
204(3)
Publicly Traded Partnerships
207(1)
Electing Large Partnerships
208(3)
Table of Cases 211(2)
Table of Internal Revenue Code Sections 213(2)
Table of Treasury Regulations and Rulings 215(2)
Index 217

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