State how the court opined on each of the tax issues


TAX Assignment

A.)

1. What Code Section discusses partnership formation under the Internal Revenue Code?

2. How does this Section differ from a corporate formation under Section 351?

3. What does it mean when we say that a partnership is a pass-through entity? Is it better for an entity to be a pass-through entity? Why or why not?

B.)

1.) Find a tax case on the internet that deals with partnership issues.

2.) Provide a citation for the case.

3.) Summarize the issues and explain what the controlling tax law consists of. This for example may be Section 721 or some Treasury Regulation or a Revenue Ruling for example.

4.) State how the court opined on each of the tax issues involved.

C.)

1. Please explain what a partnership agreement is? What does a partnership agreement usually include?

2. What is the significance of having a general partnership vs. having a limited partnership?

3. How does a partnership report income for tax purposes? What forms are used?

4. Please explain what a guaranteed payment is. How is it reported to the partners? How do the partners report it?

5. What expenditures would a brand new partnership incur? How would the costs be treated for tax purposes?

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Taxation: State how the court opined on each of the tax issues
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