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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...

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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...