Federal Tax Law

PARTNERSHIP TAX – INDEPENDENT STUDY

Spring 2005

Professor Jeffrey Kahn

Email:

Website: http://www.jeffreykahn.com/SCUPartnership.html

INTRODUCTION

The required texts for the course are: Lind, Schwarz, Lathrope, Rosenberg, Fundamentals of Partnership Taxation (Foundation Press, 6th ed.) and Selected Federal Taxation Statutes and Regulations (West Group, 2005 ed.). An older edition of the statute textbook is fine.

ASSIGNMENTS

References to pages numbers or chapters are to Lind, Schwarz, Lathrope, Rosenberg, Fundamentals of Partnership Taxation (Foundation Press, 6th ed.). The Code sections and regulations which are cited in the casebook at the beginning of new material are included in the assigned material. In addition, Code sections and regulations are included in the assignments set forth in the pages that follow. References to “IRC” numbers are to sections of the Internal Revenue Code of 1986, and all references to “Treas. Reg.” are to sections of Treasury Regulations to the Code. If the assigned regulation is not in the book, please look it up on Lexis or Westlaw.

This is an independent study. Therefore, you are responsible to learn the material on your own. You must turn in the assigned problems by the specific due date noted below. I will review the problems and return them with comments. I may ask you to redo the problems and turn them back in if I feel that it would be helpful.

1.  Pages 2-15. Note: Pages 16-25, 73-74

IRC §§ 701, 702(b), 703(b), 761(a)-(c), 7701(a)(1)-(3)

Problems

Question 1 (omit Question 1(c)), page 15

2.  Pages 28-40

Problems

Problem on page 33

Take a stab at preparing the balance sheets requested for the problem on page 40

3.  Pages 40-48

IRC § 7701(g)

Problems

Problems on page 43 and at pages 47-48

TURN IN PROBLEMS FROM ASSIGNMENTS 1-3 BY MONDAY JANUARY 31

4.  Pages 48-71
IRC § 706(d)(1), § 83(g)

Problems

Problems on pages 56-57 and pages 70-71

5.  Pages 71-72

Problems

Problem on page 72

6.  Pages 73-90

7.  Pages 90-93

Problems

Problem on page 93

8.  Pages 93-97
Note: pages 97-99

9.  Pages 99-100

Problems

Problem on page 100

TURN IN PROBLEMS FROM ASSIGNMENTS 4-9 BY MONDAY MARCH 14

10.  Pages 100-109.

Problems

Problems 1 and 2 on pages 108-109

11.  Pages 109-117

IRC §§ 706(c), 163(d)

Note: Prop. Regs. §§ 1.465-1 to 1.465-69; Temp. Reg. § 1.469-2T(d)(6)(iii)

Problems

Problems 1 and 2 on pages 116-117

12.  Pages 118-155

Problems

Problems 1-3 on pages 155-157

13.  Pages 157-167

Problems

Problem on pages 167-168

TURN IN PROBLEMS FROM ASSIGNMENTS 10-13 BY MONDAY APRIL 11

14.  Pages 174-190

Problems

Problems 1-3 on pages 189-190

15.  Pages 190-209

Note: Treas. Reg. § 1.701-2(d), Ex. (6)

Prop. Reg. § 1.168-2(k)

Problems

Problems 1-3 on pages 207-209

16.  Pages 209-214

Problems

Problems 1 and 2 on pages 213-214

TURN IN FINAL PROBLEMS BY WEDNESDAY APRIL 27