Semantics and Substance in Partnership Mergers
Darryll K. Jones
Stetson University College of Law
Tax Notes, Vol. 104, No. 14, September 27, 2004
In this report, Professor Jones argues that semantics are useful in a world in which fluency with regard to substantive partnership tax is more fantasy than reality. He uses the semantic rules applicable to partnership mergers as context. In particular, Professor Jones shows how the frequent reliance on semantics leads to an incorrect result to the extent that continuing partners in a partnership merger are incorrectly granted a nonrecognition opportunity.
Accepted Paper Series
Date posted: September 26, 2004
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