Unocal Pipeline V. Kennedy: What is the Proper Method for Reporting the Lousiana Income of a Partnership that Has Elected Out of Subchapter K?

Abstract

Taking a look at the Lousiana Court of Appeal's decision in Unocal Pipeline Co., the author asks what the proper method is for reporting the Louisiana income of a partnership that had elected out of subchapter K of the IRC. When a partnership has elected to be excluded from subchapter K, there is no partnership income to allocate, the author says. In Unocal, taxing the partners as co-owners would have been consistent with the election to be excluded from subchapter K, she writes.