Companies Mentioned

TIFD III E, Inc.

Category
Title
Summary
Date
Commentaries
Tax Law

TIFD III-E, Inc. v. United States: Second Circuit Rejects Debt Holder as Partner, Enforces § 6662 Penalties
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…
Posted:
03/21/2012
The most advanced document                
         management system in the world.

Only $59 / person / month
FeaturesLawLoop Demo
FeaturesWelcome to the Future
 Play LawLoop Demo