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Description

IRS Tax Audit Manual for Partnerships Edition

TABLE OF CONTENTS

  • Chapter 1, Initial Year Return Issues
    • INTRODUCTION
    • This chapter deals with three specific types of expenses:
    • Organizational Expenses
    • Syndication Expenses
    • Start Up Expenses.
    • Other issues covered in this chapter include the tax implications of payments made to partners:
    • IRC section 707(a) – Partner or Non-Partner
    • Receipt of a Capital or Profits Interest
    • Payments Capitalized, Deducted, or Distributed?
    • Guaranteed Payments
  • Chapter 2, Capital Accounts, Basis, and Liabilities
    • INTRODUCTION
    • Capital accounts
    • Partner’s basis in his or her partnership interest
    • Partnership’s basis in its assets
    • Contributions to the Partnership
    • Partnership liabilities
    • Accounting for Book/Tax differences
    • IRC section 754 election
  • Chapter 3, Contributions of Property with Built-in Gain or Loss IRC section 704(c)
    • INTRODUCTION
    • IRC section 704(c) in the context of non-depreciable property
    • IRC section 704(c) in the context or depreciable property IRC section 704(c) in the context of amortizable property
    • Impact of IRC section 704(c) on the sharing of non-recourse liabilities
    • The Anti-Abuse Rule
    • -Reverse” IRC section 704(c) which addresses re-valuations
  • Chapter 4, Distributions
    • Basics – Current and Liquidating Distributions
    • Disguised Sales
    • Distributions of Built-in Gain or Loss Property to a Noncontributing Partner
    • Distributions of Property to a Partner that Contributed Built-in Gain or Loss Property
    • Disproportionate Distributions
  • Chapter 5, Loss Limitations
  • Chapter 6, Partnership Allocations
    • INTRODUCTION
    • Factors considered in determining the partners’ interests in the partnership
    • Economic effect
    • Substantiality
    • Allocation of items attributable to non-recourse debt
    • Allocation of tax credits
  • Chapter 7 Dispositions of Partnership Interest
    • INTRODUCTION
    • A partner can dispose of a partnership interest in the following ways:
    • By sale to one or more of the other partners.
    • By sale to a third party.
    • By exchange of the partnership interest for other property.
    • By transfer back to the partnership in return for at least one liquidating distribution leading to a complete liquidation of the partnership interest.
    • By retirement.
    • By gift or contribution.
    • By death.
    • By surrendering the partnership interest through abandonment, forfeiture, or worthlessness of the partnership interest. Each of the above methods for disposing of a partnership interest is covered in this chapter.
    • This chapter also addresses:
    • The character of the gain or loss on the disposition of a partnership interest.
    • The effect of related debt disposition.
    • The recognition of accumulated suspended passive losses associated with a partnership interest.
  • Chapter 8 Real Estate Issues in Partnerships
    • INTRODUCTION
    • Approximately 50 percent of all partnerships are involved in the real estate business. A partnership may be involved in real estate development, construction, or leasing. Even though a partnership may not be involved in a real estate business it may own or lease real estate. This chapter covers various tax issues related to real estate such as:
    • Cancellation of Indebtedness
    • Tufts/ Non-recourse Debt and Unpaid Interest
    • Accrued Contingent Interest
    • Bankruptcy
    • Low Income Housing Tax Credit
    • Zombie Partnerships
    • Uniform Capitalization – IRC section 263A
  • Chapter 9, Tax Shelters
    • INTRODUCTION — This chapter covers:
    • Corporate Tax Shelter Characteristics
    • Office of Tax Shelter Analysis
    • Tax Shelter Disclosure
    • Partnership Anti-Abuse Regulations
    • Sham Partnership/Sham Partners
    • Judicial Doctrines
  • Chapter 10 International (Reserved)
  • Chapter 11, Family Partnerships
  • Chapter 12, Syndicated Investment Partnerships
  • Chapter 13 TEFRA GLOSSARY
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