Revised Report on Partners and Partnerships Received by the Subcommittee on Internal Revenue Taxation |
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adjusted basis adjustment to basis advisory group believes advisory group's recommendations basis adjustments basis of partnership capital assets capital gains capital interest changed to read changed to section contributed property deceased partner decedent decedent's deduction delegate described in section determined distributee partner estate tax extent fair market value following modification gain or loss gross income includible in gross income in respect interest in partnership inventory items LAURENS WILLIAMS liability limitations liquidation OPTIONAL ADJUSTMENT ordinary income organizational expenses paragraph partner's distributive share partner's interest partnership agreement partnership assets partnership basis partnership income partnership interest partnership property partnership taxable present law becomes principal partners proposed statutory language provided in section rearrangement reference to section respect to section retiring partner sale or exchange section 267 section 751 assets special rules subchapter subsection substantially appreciated successor in interest taken into account taxable income taxpayer tion transfer transferee partner treated treatment unrealized receivables WILBUR D
Popular passages
Page 19 - ... to the extent not previously includible in income under the method of accounting used by the corporation, any rights (contractual or otherwise) to payment for — "(A) goods delivered, or to be delivered, to the extent the proceeds therefrom would be treated as amounts received from the sale or exchange of property other than a capital asset, or ''(B) services rendered or to be rendered.
Page 27 - The basis of such section 38 property in the hands of the transferee is determined In whole or in part by reference to the basis of such section 38 property in the hands of the transferor.
Page 53 - partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Page 16 - Is liquidated, except that the taxable year of a partnership with respect to a partner who dies shall not close prior to the end of the partnership's taxable year.
Page 26 - ... (b) Adjustment to basis of partnership property. In the case of a transfer of an interest in a partnership by sale or exchange or upon the death of a partner, a partnership with respect to which the election provided in section 754 is in effect shall— (1) Increase the adjusted basis of the partnership property by the excess of the...
Page 13 - Change of annual accounting period. If a taxpayer changes his annual accounting period, the new accounting period shall become the taxpayer's taxable year only if the change is approved by the Secretary or his delegate.
Page 43 - Increase in partner's liabilities. Any increase in a partner's share of the liabilities of a partnership, or any increase in a partner's individual liabilities by reason of the assumption by such partner of partnership liabilities, shall be considered as a contribution of money by such partner to the partnership.
Page 10 - ... in subsection (b) ) shall be allowable as a deduction ratably over a period of 60 months, beginning with the month in which the property is placed in service. The deduction provided by this section with respect to such expenditure shall be in lieu of any depreciation deduction otherwise allowable on account of such expenditure. (b) SECTION 188 PROPERTY. — For purposes of this section, the term "section 188 property...
Page 49 - Claim for credit or refund of an overpayment of any tax imposed by this title in respect of which tax the taxpayer is required to file a return shall be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the time the tax was paid...
Page 16 - The taxable year of a partnership shall not close as the result of the death of a partner...