Partnership terminated in year assets were distributed even though other assets were retained as a preserve against potential claims
Article Abstract:
In an unpublished opinion, the 6th Circuit in Goulder v. US (1995) addressed the issue of whether a partner could claim a capital loss on the dissolution of a partnership even if funds were retained as a reserve against potential claims. The appeals court ruled that there is no per se rule that the mere retention of certain assets or management of particular activities in anticipation of liabilities amounts to a continuation of a partnership.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1996
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Recent cases and rulings
Article Abstract:
Contemporary taxation cases and decisions involving partnerships are presented. Among the cases include a bankrupt partner's discharge of a partnership recourse debt share, a partner's sale of a partnership interest to another with a hold harmless agreement, a tax shelter partnership extended due to intent to evade tax exhibited by signing partner, and the waiver of right to contest validity of partnership's waiver of statute of limitations.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1997
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Tax consequences of a Bankrupt Partner's Discharge of His Share of Partnership Recourse Debts
Article Abstract:
The court ruled that a payment liquidating a promissory note and the interest of a partner in the partnership is deemed to be a distribution.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1997
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