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Logic of Subchapter K A Conceptual Guide to Taxation of Partnerships, 4th

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ISBN-10: 0314199853

ISBN-13: 9780314199850

Edition: 4th 2011 (Revised)

Authors: Laura E. Cunningham, Noel B. Cunningham, Noel B. Cunningham

List price: $86.00
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This product is designed to guide students through the conceptual framework of subchapter K. The material avoids neither the hard questions nor the conceptual difficulties, leaving students with a firm understanding of partnership taxation. Each chapter begins with a basic explanation of the relevant provisions and the roles that they play in the overall structure of subchapter K. It includes an increasingly detailed discussion of the specific rules, including multiple illustrative examples. Each chapter builds on the earlier chapters, leading the student through subchapter K. It is appropriate for J.D. or graduate-level law school courses on partnership taxation.
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Book details

List price: $86.00
Edition: 4th
Copyright year: 2011
Publisher: West Academic
Publication date: 12/20/2010
Binding: Paperback
Pages: 295
Size: 6.25" wide x 9.00" long x 0.50" tall
Weight: 1.166
Language: English

Table of Cases
Table of Code Sections
Table of Revenue Rulings
Table of Regulations
Choice of Entity: What is a Partnership for Tax Purposes?
Definition of Partnership
Choice of Form of Doing Business
Electing Partnership Treatment: The "Check the Box" Regulations
The Competing Concepts: Aggregate Versus Entity
Partnership Formation: The Basics
Basic Statutory Scheme
Common Issues on Formation
Property vs. Services
Contributions of Appreciated (or Depreciated) Property
Contribution of Depreciable Property
Characterization of Gains and Losses From the Disposition of Contributed Property
An Interim Example
Liabilities-In General
Contribution of Encumbered Property
Contributions of Accounts Receivable and Payable
Organization and Syndication Expenses
Partnership Operations: The Basics
Partnership Taxable Years
Method of Accounting
The Computation of A Partnership's Taxable Income
In General
Separately Stated Items
Partnership Elections
Adjustments to the Partners' Outside Basis
Financial Accounting and Maintenance of Capital Accounts
Essential Elements of Financial Accounting
Basic Capital Accounting Rules
Introduction to Tax Capital Accounts: Contributions and Revaluations
Partnership Allocations: Substantial Economic Effect
"Substantial Economic Effect"
The Significance of Capital Accounts: The Orrisch Case
Codification of Substantial Economic Effect
The � 704(b) Regulations
In General-Structure
Substantial Economic Effect
A Limitation-Family Partnerships
The Allocation of Nonrecourse Deductions
Contributions of Property: Section 704(c) and Section 704(c) Principles
Contributions of Property
Nondepreciable Property
Depreciable Property
Choice of Methods
Anti-abuse Rules
Partnership Liabilities
A Preliminary Issue: What is a Liability?
The Regulations Governing � 1.752-1 Liabilities
Economic Risk of Loss
Sharing Recourse Liabilities
Illustration-Recourse Liabilities
Partners Providing Property as Security for Partnership Debt
Sharing of Nonrecourse Liabilities
Transactions (Other than Sales) between a Partnership and its Partners
Sections 707(a) and 707(c)
Disguised Capital Expenditures: � 707(a)(2)(A)
Receipt of Partnership Interest in Exchange for Services
A Final Note: Pending Legislation
The Sale of a Partnership Interest
The Seller
Statutory Scheme
Section 751(a) Property
Section 751(a) Computation
Installment Sales of Partnership Interests
The Buyer
Effect of the Adjustment
Related Matters-�� 706(c) & (d)
Closing a Partnership's Taxable Year
Allocation of Income for the Year of Change
Distributions-The Basics
Preliminary Issues
Sections 706(c) & (d)
Capital Accounting Rules
Character and Holding Period of Distributed Property
Basis of Partnership's Undistributed Property
Recognition of Gain or Loss
Basis of Distributed Property
Current Distributions
Liquidating Distributions
Special Rule under � 732(d)
Partnership Termination
Optional Basis Adjustment-� 734(b)
Determination of the Amount of the Adjustment-Section 734(b)
Allocating the Adjustment Among Partnership Assets-Section 755
Final Thoughts
Disproportionate Distributions
Section 751(b): The "Evil" and The "Cure"
The "Evil"
The "Cure"-� 751(b)
Additional Examples
Final Observation
Retirement and Death of a Partner
Section 736(b)-Deferred Liquidation Payments
Section 736(a) Payments
The Relationship between � 736 and � 751(b)
Death of a Partner
Disguised Sales and Exchanges
Disguised Sales of Property
The Regulations Under � 707(a)(2)(B)
Two-Year Presumptions
Normal Distributions
Sections 704(c)(1)(B) and 737
Section 704(c)(1)(B)
Section 737
Disguised Sales of Partnership Interests
The Partnership Anti-Abuse Rules
The General Anti-Abuse Rule
Intent of Subchapter K
Facts and Circumstances
Abuse of Entity Rule
Is the Anti-Abuse Regulation Valid or Necessary?