Partnership procedure

Article Abstract:

The US government had mailed a notice of final partnership administrative adjustment to Alexander to inform him of adjustments on his partnership's return in 1984. Alexander filled up Form 870-P titled 'Settlement Agreement for Partnership Adjustments' signifying his acceptance of the adjustments. A deficiency was assessed by the Service. Alexander filed for a claim for refund but was disallowed by the Service. The Fifth Circuit decided that the binding settlement agreement did not preclude a refund of an assessed deficiency.

Cases, Tax refunds

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How to exploit the interaction between Subchapter K and the alternative minimum tax

Article Abstract:

Taxpayers are required to compute their income tax under the regular, alternative minimum tax (AMT), and adjusted current earnings systems. Subchapter K rules parallel those of the AMT. Taxpayers are not restricted from partnerships under the AMT. Despite the added computations and records, they can exploit opportunities offered by the possible interaction of AMT and partnership rules that would benefit partnership transactions.

Interpretation and construction, Tax law, Minimum tax

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Liquidating the partnership: an analysis of the issues and opportunities

Article Abstract:

Partnership termination for federal tax purposes follows the partnership liquidation. In general, the Code provides for the nonrecognition of gain or loss by partners and partnerships on property distributions. Practitioners should be kept abreast of the complicated issues of partnership liquidation to minimize gain recognition and maximize the allotment of basis among the assets apportioned.

Tax Management, Partnerships, Laws, regulations and rules, Tax accounting, Tax planning, Liquidation

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