Friday, August 30, 2013

Polishing Subchapter K: Part XIV

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Section 735(a)(1) provides that unrealized receivables distributed by a partnership to a partner generate ordinary income when the partner s...
Wednesday, August 28, 2013

Polishing Subchapter K: Part XIII

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One of the most vexing aspects of subchapter K is the complexity of the optional and special basis adjustments under sections 732(d), 734(b)...
Monday, August 26, 2013

Polishing Subchapter K: Part XII

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Section 751 is a subchapter K provision designed to ensure that gain or loss attributable to ordinary income assets in a partnership is char...
Friday, August 23, 2013

Polishing Subchapter K: Part XI

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The extent to which guaranteed payments affect adjusted basis in a partnership interest is unclear. This is yet another question for which t...
Wednesday, August 21, 2013

Polishing Subchapter K: Part X

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Section 704(e)(2), which attempts to apply two assignment of income doctrines to partnerships, is difficult to read, challenging to explain,...
Monday, August 19, 2013

Polishing Subchapter K: Part IX

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In determining whether a partnership exists, it is necessary to identify at least two partners. The question of whether a individual or enti...
Friday, August 16, 2013

Polishing Subchapter K: Part VIII

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One of the more complicated areas of Partnership Taxation is the treatment of contributed property. Sections 704(c) and 737 are challenging,...
Wednesday, August 14, 2013

Polishing Subchapter K: Part VII

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For students who think that tax law is nothing more than a set of rules that they need to memorize, I emphasize that there are numerous situ...
Monday, August 12, 2013

Polishing Subchapter K: Part VI

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The language of section 705, which provides for the computation of a partner’s adjusted basis in a partnership interest, is unwieldy and req...
Friday, August 09, 2013

Polishing Subchapter K: Part V

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For as long as I had been teaching Partnership Taxation, students have asked why section 707(b) exists. The question is not why the substant...
Wednesday, August 07, 2013

Polishing Subchapter K: Part IV

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Under sections 771 through 777, certain partnerships with 100 or more partners are permitted to elect simplified treatment for computing tax...
Monday, August 05, 2013

Polishing Subchapter K: Part III

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The treatment of charitable contributions as not part of a partnership’s taxable income under section 703(a)(2)(C) adds unnecessary complexi...
Friday, August 02, 2013

Polishing Subchapter K: Part II

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Though the debate over the treatment of carried interests has been long, deep, and intense, for me, the solution is easy. To the extent that...
Wednesday, July 31, 2013

Polishing Subchapter K: Part I

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Now that, barring unexpected and extraordinary developments, I am no longer teaching Partnership Taxation, it is an appropriate time to shar...
Monday, July 29, 2013

Tax Law and National Defense: Hush Now!

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When I was a child I was told, and of course I long since saw actual evidence, that during World War II Americans were encouraged to be very...
Friday, July 26, 2013

The Tax Cost of Contract Procrastination

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A recent Tax Court Case, Williams v. Comr. , T.C. Summ. Op. 2013-60, demonstrates yet again why it is important to put things in writing in ...
Wednesday, July 24, 2013

Tax Policy Flaw Just Part of a Bigger Problem

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Readers of MauledAgain know that I am a harsh critic of the foolish claim that reducing tax rates increases revenue. The chief flaw of that ...
Monday, July 22, 2013

Lap Dance Tax?

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A reader sent along an interesting story about the City of Philadelphia’s assessment of a tax against establishments that provide lap dance...
Friday, July 19, 2013

In Tax, As in Much Else, Precision Matters

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A recent Tax Court case, Nye v. Comr. , T.C. Memo 2013-166, illustrates why document drafters need to pay close attention to what they are d...
Wednesday, July 17, 2013

More Proof of How Privatization Harms Taxpayers

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Among the many political decision that I consider foolish, privatization of functions that belong in the public arena is high on the list. P...
Monday, July 15, 2013

An Honor System for Federal Taxes?

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Mike Razar, at American Thinker suggests, surely tongue-in-cheek, that the federal tax system should be reformed by abolishing the IRS and...
Friday, July 12, 2013

How I Ended Up Teaching Tax (and Other Things): Part XII

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One of the questions posed to me, especially by several high school and elementary school classmates, is how the math-and-science guy ended ...
Wednesday, July 10, 2013

How I Ended Up Teaching Tax (and Other Things): Part XI

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Two of the tasks that teachers do, though some don’t list it among their most favorite aspects of teaching, are creating examinations, quizz...
Monday, July 08, 2013

How I Ended Up Teaching Tax (and Other Things): Part X

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In the first class of any of my courses, one of the points I try to get across to my students is that we are teaching them to teach. I expla...
Friday, July 05, 2013

How I Ended Up Teaching Tax (and Other Things): Part IX

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At about the same time that I was engaged in tutoring during my third year in law school, another of my professors with whom I had also beco...
Wednesday, July 03, 2013

How I Ended Up Teaching Tax (and Other Things): Part VIII

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Early in my third year of law school, one of my professors with whom I had become, and with whom I remain, friends, sat me down and asked me...
Monday, July 01, 2013

How I Ended Up Teaching Tax (and Other Things): Part VII

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Law school started for me as it does for most first-year students. It was different, it was bewildering, it was interesting, it was fast-pac...
Friday, June 28, 2013

How I Ended Up Teaching Tax (and Other Things): Part VI

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After I graduated from high school and entered college, I continued to tutor high school students in several subjects. These students were n...
Wednesday, June 26, 2013

How I Ended Up Teaching Tax (and Other Things): Part V

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High school brought another opportunity to teach. Two thoughts coalesced in my mind. One was that I enjoyed teaching. The other was that it ...
Monday, June 24, 2013

How I Ended Up Teaching Tax (and Other Things): Part IV

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By the time I reached high school, I had learned to pipe down in the classroom, though I wasn’t in it all that much by the time I was in eig...
Friday, June 21, 2013

How I Ended Up Teaching Tax (and Other Things): Part III

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My next foray into teaching also has its roots in the struggles that the elementary school teachers encountered trying to deal with me in th...
Wednesday, June 19, 2013

How I Ended Up Teaching Tax (and Other Things): Part II

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My earliest memory of engaging in teaching activities takes me back to fourth grade. It’s possible that I was teaching before that time. Sur...
Monday, June 17, 2013

How I Ended Up Teaching Tax (and Other Things): Part I

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Every once in a while, someone asks me how or why I ended up teaching tax, or teaching in a law school. There are two versions of the story....
Friday, June 14, 2013

Potholes: Poster Children for Why Tax Increases Save Money

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On several occasions in the past, I have tried to make the point that the cost of stopping tax increases can exceed the tax increase thereby...
Wednesday, June 12, 2013

Reactions to “Parents to Children: Be a Lawyer, Marry a Lawyer”

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My recent post, Parents to Children: Be a Lawyer, Marry a Lawyer , generated a response from a reader. He sent me several links, including M...
Monday, June 10, 2013

Code-Sized Ignorance Discussion Also Is Growing

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It started with Bush Pages Through the Tax Code? , and continued with Anyone Want to Count the Words in the Internal Revenue Code? , Tax Com...
Friday, June 07, 2013

Parents to Children: Be a Lawyer, Marry a Lawyer

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The results of a new survey by the blog lawyers.com reveals some surprising or perhaps not so surprising perspectives. The survey disclosed...
Wednesday, June 05, 2013

Code-Size Ignorance Knows No Boundaries

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For almost nine years, I have been trying educate people about the size of the Internal Revenue Code. Trying to eliminate the woeful ignoran...