TIFD III E, Inc.
The Second Circuit recently found that partners whose interests are bound by overwhelmingly debt-like features are not partners for tax purposes. In TIFD III-E, Inc. v. United States, 666 F.3d 836 (2d. Cir. 2012), the Second Circuit rejected taxpayer’s argument that I.R.C. § 704(e)(1) broadened existing law to include debt…