Partnership Taxation
The book provides an Introduction to the federal income taxation of partners and partnerships. The first six chapters explain how the income of the partners is taxed, and how the law achieves its objective of disregarding the business entity and taxing the partners directly. Chapters one through three focus on the classification of business entities, the pass through of a partnership's tax items to partners of the partnership, and the concept of partnership capital accounts. Chapters four through six examine the questions of how the partnership's tax items must be allocated among the partners. Chapters seven through nine consider transfers of partnership interests, contributions to and distributions from partnerships, and potential recharacterization of these transactions. ten address the tax consequences of compensating partners for services and use of capital. Chapter eleven discusses partnership terminations. The last chapter explores special anti-abuse rules that limit opportunities for abuse of law.