Abstract

http://ssrn.com/abstract=2126529
 
 

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Contribution of a Built-In Loss to a Partnership


Douglas A. Kahn


University of Michigan Law School

July 30, 2012

Tax Notes, Vol. 136, No. 5, 2012
U of Michigan Law & Econ Research Paper, No. 12-015

Abstract:     
In 2004, Congress amended the Code to prevent the use of a partnership entity as a means of transferring the potential deduction for a built-in loss from one person to another. The amendment was poorly designed in such manner that it often distorts the reporting of taxable income. Moreover, the amendment has undermined the application of the remedial method and the traditional method with curative allocations to a contribution of a built-in loss.

Number of Pages in PDF File: 8

Keywords: built-in loss, partnership taxation, contributing partner, contributed property, remedial method

JEL Classification: K34

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Date posted: August 8, 2012 ; Last revised: August 19, 2012

Suggested Citation

Kahn, Douglas A., Contribution of a Built-In Loss to a Partnership (July 30, 2012). Tax Notes, Vol. 136, No. 5, 2012; U of Michigan Law & Econ Research Paper, No. 12-015 . Available at SSRN: http://ssrn.com/abstract=2126529

Contact Information

Douglas A. Kahn (Contact Author)
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4043 (Phone)
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