Search

Home > Personal Income Tax Planning > Economic Substance, Promissory Notes and Partnerships - Ed Zollars
Podcast: Personal Income Tax Planning
Episode:

Economic Substance, Promissory Notes and Partnerships - Ed Zollars
Category: Business
Duration: 00:00:00
Publish Date: 2008-01-13 20:10:42
Description: This PodCast concerns the economic substance doctrine. We look at a case where the IRS failed in an attempt to argue that a transaction had no economic substance or otherwise failed under the anti-abuse partnership regulations. The case is Countryside Limited Partnership v. Commissioner, TC Memo 2008-3 where the taxpayers used the partnership distribution rules to allow two partners to have their interests in the partnership liquidated with no tax cost just prior to the partnership selling a significant asset at a gain.

The materials are located at http://www.edzollars.com/2008-01-14_Partnership.pdf .



This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com

Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Total Play: 0

Some more Podcasts by Steve Leimberg

60+ Episodes
Trusts 3    
90+ Episodes
Corporate Ta .. 5    
90+ Episodes
Corporate Ta ..