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Tax Returns, Examinations & IRS Procedure

This library contains hundreds of high-quality technical tax memoranda on a wide variety of topics. The memoranda are organized by topics and are fully word-searchable. This library is a rich resource of already-solved tax problems. Use it as a starting point for your own research.

The Tax Resource Group Memo Library Category: Partnership Taxation Affiliated Service Groups; Effect of One Shareholder Establishing Qualified Medical and Retirement Plans; IRC: 414(m); 105(h). Amortization of Goodwill; Amortization of Goodwill Resulting from Section 743(b) Step-Up; IRC: 743(b), 197, 754, 755. Basis and Losses; Preserving Basis-Limited Losses; IRC 704(d). Contribution of Loss Property to Partnership; Interaction of Section 1015 and the Partnership Basis Rules; IRC: 1015, 704(c), 722. Contribution of Property to Partnership; Disclosure Requirements; IRC: 721. Conversion of General Partnership to LLC; Mechanics of Conversion, Related Tax Issues; IRC: 731(a)(1). Conversion of S Corporation to LLC; Basis of Assets Contributed to Newly-Formed LLC; IRC: 336(b), 723, 334, 7701(g). Development Activities; Dealer Status; IRC: 1221. Donation of Partnership Interest; Part Gift, Part Sale--Donation of Encumbered Partnership Interest; IRC: 751, 1011(b). Examinations; Statute of Limitations for Partnership Examinations; IRC: 6229, 6231. Gift of Limited Partnership Interest; Various Issues; IRC: 1001, 1041. Incorporation of Partnership; Effect of Alternative Methods of Incorporation; IRC: 351, 368(c). Installment Sale to Controlled Partnership; Related Party Installment Sales, Recharacterization of Gain on Sale Between Related Parties; IRC: 1239, 453(g), 267. Jointly Owned Property; Electing Out of Partnership Provisions; IRC: 731, 732, 168(i)(7). Like-Kind Exchange; Various Issues; IRC: 1031, 1250, 1231, 291. LLC; Tax Matters Partner of LLC; IRC: 6231. Medical Savings Account (MSA); MSA for Partners and S Corporation Shareholders; IRC: 105, 106, 1372(a), 707(c). Merger of LLCs; Merger of LLCs; IRC 708, 721, 732. Multi-Tier Partnerships; Section 754 Election/Timing of Theft Loss from Embezzlement; IRC: 165(e), 754, 743(b). Nonresident Alien Limited Partners, Taxation of; Various Issues; IRC: 1231, 1441, 871, 875(1), 6012. One-Person LLCs; Classification Rules; Type of Tax Return; IRC 7701. Partners as Employees; Discussion of Ineligibility of Partners to Also be Employees; IRC: 707. Partnership; Withholding Requirements for Partnership with Foreign Partners; Filing Requirements U.S. Partners; IRC: 704, 871, 1445, 1446, 875. Partnership Disguised Sale Rules; Applicability of Partnership Disguised Sale Rules; IRC: 707(a), 721, 752. Partnership Expenses; Expenses Incurred by General Partner; IRC: 162, 212. Partnership Interest for Services; Restrictions on Sale--Timing Issues; IRC: 83(a). Partnership Interests; Acquisition of Partnership Interests; IRC: 708(b)(1)(B), 704, 752, 482, 267. Partnership Losses; Mitigation of Statute of Limitations; IRC: 1311 through 1314. Partnership Property, Sale of; Effect of Related Parties on Installment Sale and Character of Income; IRC: 1231, 707(b), 453(g), 731. Partnership Terminations; Recapture of Negative Capital Account; Termination of Partnership; IRC: 708(b)(1)(B). Passive Activity, Disposition of; Assignment as Complete Disposition; IRC: 469(g), 172. Payment to Protect Business Reputation; Discussion of Deductibility of Payments; IRC: 162. Payments From A Partnership; Redemption of Partnership Interest; IRC: 736, 751. Payments From A Partnership; Retiring Partner; IRC 736. Sale of Dealer Notes; Sale of Dealer Notes Between Related Parties; IRC: 1221(4), 267(a)(1) and 707(b). Section 108 Qualified Real Property Indebtedness; Interaction with Insolvency Exception/Mechanics of Election; IRC: 108. Section 754 Election; Effect of 754 Election and Subsequent Foreclosure Gain; IRC 754. Section 1031 Exchanges; Partnership Property, Replacement Property--Change of Intent; IRC: 1031. Technical Terminations; Buyout Resulting in a One-Member LLC; IRC: 754, 708(b)(1)(A), 732(c), 732(d), 1231, 743(b). Termination/754 Election; Late 754 Elections; IRC 754, 708(b)(1)(B), 9100. Termination/754 Election; Termination of Partnership--Section 754 Election--Mechanics Under Old vs New 708 Regs; IRC 708, 754. Transfer of Assets; Effects of Transfer of Assets from Corporation to Partnership; IRC: 501(c)(3), 1060, 168(f)(5)(B)(iii).