- What Code Section discusses partnership formation under the Internal Revenue Code?
- How does this Section differ from a corporate formation under Section 351?
- 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?
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.
- Please explain what a partnership agreement is? What does a partnership agreement usually include?
- What is the significance of having a general partnership vs. having a limited partnership?
- How does a partnership report income for tax purposes? What forms are used?
- Please explain what a guaranteed payment is. How is it reported to the partners? How do the partners report it?
- What expenditures would a brand new partnership incur? How would the costs be treated for tax purposes?