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Partners Allocated "COD" Income
January 15, 2021
In 2009, H, B, along with BO, and R formed E. E was in the business of text message advertising. E's partners entered into an operating agreement. That agreement stated tha...

"Robert Willens LLC is neither a registered investment advisor nor a broker/dealer. Subscribers and/or readers are advised that the information contained in The Willens Report is not to be construed or relied upon as investment, tax planning, accounting and/or legal advice, nor is it to be construed in any way as a recommendation to buy, hold or sell (short or otherwise) any security or any other form of investment. All opinions, analyses and information contained herein is based upon sources believed to be reliable and is written in good faith, but no representation or warranty of any kind, express or implied, is made herein concerning any investment, tax, accounting and/or legal matter or the accuracy, completeness, correctness, timeliness and/or appropriateness of any of the information contained herein. Subscribers and/or readers are further advised that the Company does not necessarily update the information and/or opinions set forth in this and/or any subsequent edition of The Willens Report or any version thereof. Readers are urged to consult with their own independent professional advisors with respect to any matter analyzed herein. All information contained herein and/or this website should be independently verified."


Recent Reports

I.R.S. Issues Rare Sec. 1221(a)(1) Ruling
January 15, 2021
TP is a REIT. TP owns and leases residential real estate to third parties. LP owns in excess of "a%" of all classes of stock of TP and all ofTP's...
Trailers Are Not Exempt "Truck Bodies"
January 15, 2021
Petitioner is the owner of BT LLC, ("B"). B sells trailer-type vehicles. During the dates at issue in this matter, B sold trailer-type vehicles to non-Wisconsin resid...
Restitution And Remediation Are Deductible
January 15, 2021
The I.R.S. recently issued final regulations regarding the controversial topic of the deductibility of "fines, penalties, and other amounts." The statute governing th...
"Internal" Spin-Off Not A "Disqualified Distribution"
January 14, 2021
P acquired Sub 1 on DateA, a date less than five years ago.Sub 1 owns all of the stock of Sub 2. Sub 2 owns all of the stock of EE. EE owns D. D is regula...