Sec. 704(c)'s anti-abuse rule: a practitioner's guide.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on May 1, 1997. The length of the article is 1657 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: IRC section 704(c) is designed to prevent partners in a partnership from shifting tax attributes around to reduce tax liability related to contributed property. The regulations provide for permissible allocation methods and identify when the anti-abuse provisions may be triggered. The anti-abuse provisions will not be triggered when the contributing and non-contributing partners are in the same tax brackets and when the ceiling rule has not affected the allocation of items. Some transactions are not clearly covered by or exempt from the anti-abuse provisions.

Citation Details
Title: Sec. 704(c)'s anti-abuse rule: a practitioner's guide.
Author: Walter R. Drew
Publication:The Tax Adviser (Magazine/Journal)
Date: May 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n5 Page: 282(2)

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