Federal Taxation Of Partnerships And Partners

Common Law and Equitable Remedies for Breach of Contract; Expectation Damages; Restitution; Reliance Damages; Specific Performance; Contracts for the Sale of Goods: Buyers' and Sellers' Remedies Under Article II of the UCC; Remedies Available to Buyer When He Has Not Accepted the Goods; Remedies Available to Buyer After He Has Accepted the Goods, Including Remedies for Breach of Warranty; Remedies Available to Seller When Buyer Defaults and Has Not Accepted the Goods; Remedies Available to Seller After Buyer has Accepted the Goods; Contractual Control Over Remedy; Liquidated Damages Clauses; Contractual Modification or Limitation of Remedy Under UCC 2-719; Remedies for Mistake and Unconscionability; Mistake in the Formation of an Agreement -- The Recission and Restitution Remedies; Mistake in Integration or Expression The Reformation Remedy: Mistake in Performance of an Obligation The Restitution Remedy; Unconscionability.

Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.

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. 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's seamless web. For J.D. or graduate-level law school courses on partnership taxation.

Treatise on the federal taxation of partnerships and partners in the U.S. The various chapters consider: general concepts; acquisitions of partnership interests; basis of a partner's partnership interest and the impact of partnership liabilities; tax aspects of partnership operations; audit and litigation; distributive share rules; terminations; partnership-partner transactions; family partnership rules; transfers of partnership interests; partnership distributions; death or retirement of a partner; adjustments to the basis of partnership assets.

This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised edition reflects developments through September 2012, including codified economic substance doctrine and penalty provisions; choice of business form and classification of series entities; at-risk and passive loss rules as applied to LLCs and LLPs; partnership debt-equity exchanges and proposed carried interest legislation; new rules on accounting for partner's varying interests in the partnership; and disguised sale transactions and recent tax-shelter decisions.