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A Technical Analysis of Proposed Section 710

20 Pages Posted: 22 Nov 2007 Last revised: 19 Jun 2012

Howard E Abrams

University of San Diego School of Law


In general, a partner's distributive share takes its characterization from the activities of the venture. Proposed section 710 will rechararterize as compensation the distributive share of any partner who contributes services to the partnership. It also recharacterizes as a sale certain distributions of property to a service partner. This paper examines proposed section 710 in detail and concludes that it is poorly conceived and inappropriately implemented.

Keywords: K34

JEL Classification: law, tax, partnership tax

Suggested Citation

Abrams, Howard E, A Technical Analysis of Proposed Section 710. Tax Notes, Vol. 117, p. 961, December 3, 2007; Emory Public Law Research Paper No. 07-25. Available at SSRN:

Howard E. Abrams (Contact Author)

University of San Diego School of Law ( email )

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