Making Partnerships Work for Mom and Pop and Everyone Else

56 Pages Posted: 18 Aug 2011

See all articles by Emily Cauble

Emily Cauble

DePaul University - College of Law

Date Written: August 17, 2011


Entities treated as partnerships for tax purposes cover the spectrum from small Mom and Pop operations to mammoth enterprises owned by sophisticated partners. Designing tax law to govern this diverse array of entities is a challenging exercise since rules that are well suited to provide simplicity for entities at the small, unsophisticated end of the continuum may be poorly designed for preventing manipulation by entities at the large, sophisticated end of the continuum. However, a careful examination of how tax rules can best promote simplicity reveals opportunities for reform that would make the law more appropriate for entities all along the continuum.

Keywords: Partnership Tax, Complexity, Section 704(c), Section 754

Suggested Citation

Cauble, Emily, Making Partnerships Work for Mom and Pop and Everyone Else (August 17, 2011). Columbia Journal of Tax Law, Vol. 2, No. 2, 2011, MSU Legal Studies Research Paper No. 09-17, Available at SSRN:

Emily Cauble (Contact Author)

DePaul University - College of Law ( email )

25 E. Jackson Blvd.
Chicago, IL Cook County 60604-2287
United States

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