PARTNERSHIP TAXATION
Spring 2001 Syllabus
Professor Allington
This course covers federal income taxation of partnerships and partners, including limited partnerships, limited liability partnerships, and limited liability companies.
Required Materials
T. Allington, Partnership Taxation (2001)
Dickinson, Federal Income Tax Code and Regulations, Selected Sections (2000-2001 ed., CCH)
Assignments
An outline of topics covered in the course is included below. Assignments will be posted weekly on the Web, with a link from the course Web page at:
http://www.iulaw.indy.indiana.edu/Instructors/Allington/Partnership.htm
Attendance
The law school’s attendance policy provides that a student who is absent from more than 10 percent of the classes may be dropped from the course. You will be dropped from this course if you are absent from more than four classes.
Class Preparation
Most of the class discussion will focus on the assigned problems in the casebook. For each class, you should read the assigned pages in the casebook and the Internal Revenue Code sections cited for each topic. Skim the regulations cited for each topic. Be prepared to discuss the problems in the casebook for each assignment.
Examination
Your grade will be based on an examination, which is scheduled for Friday, April 27, 2001 at 9:00 a.m. The exam will consist of essay questions similar to the problems in the casebook. It will be an open book exam, limited to the casebook, the Code and Regulations, and any notes or outlines you have prepared yourself.
Secondary Materials
K. Burke, Federal Income Taxation of Partners and Partnerships in a Nutshell 2d ed., 1999, West Group)
L. Cunningham & N. Cunningham, The Logic of Subchapter K: A Conceptual Guide to the Taxation of Partnerships (2d ed., 2000, West Group) (paperback)
A. Gunn, Partnership Income Taxation (3d ed., 1999, Foundation Press) (paperback)
W. McKee, W. Nelson & R. Whitmire, Federal Taxation of Partnerships and Partners (3rd ed. 1996, Warren, Gorham & Lamont) (two-volume treatise)
A. Willis, J. Pennell & P. Postlewaite, Partnership Taxation (6th ed. 1997, Warren, Gorham & Lamont) (two-volume treatise)
Partnership Taxation
I. Partnership Status pp. A. Partnerships Distinguished from Corporations 1-17 B. Partnerships Distinguished from Other Business Arrangements 17-31 II. Formation of a Partnership A. Partnership Interest Acquired in Exchange for Property 32-47 B. Partnership Interest Acquired in Exchange for Services 47-67 III. Taxation of Partnership Operations A. Entity v. Aggregate Concepts 68-85 B. Partnership Taxable Income 85-94 C. Partnership Elections 94-99 IV. Partners' Distributive Shares A. Substantial Economic Effect 100-115 B. Partner's Interest in the Partnership 115-123 C. Allocations of Items Without Economic Effect 123-125 D. Contributed Property 125-129 E. Varying Partnership Interests 129-134 V. Limitations on Deduction of Partnership Losses A. Basis 135-138 B. At Risk 138-139 C. Passive Losses 139-150 VI. Transaction Between Partners and Partnerships A. Payments for Services and the Use of Property 151-156 B. Sales and Exchanges of Property 156-157 VII. Family Partnerships A. Existence of a Partnership 158-171 B. Allocation of Distributive Shares 171-172 C. Estate Planning 172-186 VIII. Sale or Exchange of a Partnership Interest A. Allocation of Distributive Shares 187-1891 B. Amount Realized and Adjusted Basis 189-201 C. Character of Gain or Loss 201-212 D. Transferee's Basis 212-215 IX. Partnership Distributions A. Nonliquidating 216-222 B. Liquidating 222-224 C. Optional Basis Adjustments 224-225 D. Distributions Altering Partners' Interests in Unrealized Receivables and Inventory 225-231 X. Withdrawal or Retirement of a Partner A. Payments to a Withdrawing Partner 232-234 B. Installment Payments 234-235 C. Liquidation v. Sale 235-244 D. Abandonment or Worthlessness 244-247 X1. Death of a Partner A. Termination of the Partnership 248-249 B. Basis Adjustments 249-264
| Home | Assignments | IU Law-Indy |