Table of Contents
Chapter 1 - Partnership Taxation - Section 1
Definition of Trade or Business
Exception - Separate Entity for Some Purposes
Partnership Expenses Paid By a Partner
Character of Items & Limitations
Outside Basis Limitation - '704(d)
Effect of Losses on Outside Basis - '705
Organization & Syndication Fees - '709
Business Start-up Costs - '195
Failure to Furnish Copies to Partners
Limitation on Choice of Taxable Year
Limitations on Changing a Tax Year
Making the Election - Form 8716
Transactions between Partner and Partnership
Treating Partner as Stranger - '707(a)
Payments by Accrual Basis Partnership to Cash
Basis Partner
Prepaid & Capital Expenses - '707(c)
Organization & Syndication Expenses - '709
Stranger Payment vs. Guaranteed Payment
Recipient of Salary as an Employee
Accident & Health Insurance Premiums
Certain Losses Disallowed - '707(b)
Chapter 1 - Section 1 Review Questions
Chapter 1 - Partnership Taxation - Section 2
Contributions of Property - '721
Contribution vs. Sale or Exchange
Disguised Taxable Exchanges - '704 & '737
Precontribution Gain or Loss Property
Property Distribution to Contributing Partner -
'737
Contributed Property Distribution to Another
Partner - '704(c)
Seven Year Period (Formerly Five)
Allocation Methods for Precontribution Gain or
Loss
Transfers to Investment Company Type Partnerships
- '721(b)
Contributed Assets Inside (Partnership) Basis -
'723
Allocations as to Contributed Property - '704(c)
Earlier Optional Application of '704(c)
Character of Subsequent Loss - '724(c)
Basis of Partners Interest - Outside Basis
Deemed Distribution & Contribution
Special Rule for Liabilities of Cash Basis
Partnership
Partners Share of Partnership Liabilities
Sales & Exchanges of Partnership Interests
Capital Asset Treatment - '741
Importance of Capital Treatment
Regs on Gain on Sale of Passthrough Entities -
'1(H)
Transfers to Controlled Corporations - '351
Foreign Person Sale of U.S. Partnership Interest
Inside Basis after Transfer of Partnership
Interest
Substantial Built-in Loss - '743(d)
Special Inside Basis Adjustment - '754 &
'743(b)
General Nonrecognition Rule - '731
Liquidating or Complete Distribution
Allocation of Basis When Limited - '732(c)
Partnerships Basis Greater Than Partners Basis
Partners Basis Greater Than Partnerships Basis
Partnership Property - '754 & '734
Basis Allocation on Properties Distributed By a
Partnership
Types of Liquidating Distributions
Liquidating Distributions of Money
Exclusions From '736(b) Treatment
Basis Adjustment after Distributions
Additional Adjustments Required by '734