An Unprofitable Pretax Venture Can Still Be a Partnership
171 Tax Notes Fed. 1951 (June 21, 2021)
6 Pages Posted: 15 Jul 2021
Date Written: June 21, 2021
Abstract
We use machine-learning models to analyze and anticipate the outcome of the IRS’s appeal of the Tax Court's decision in Cross Refined Coal LLC v. Commissioner, No. 19502-17 (2019) (bench op.). We predict that the D.C. Circuit will hold that the taxpayer had been carrying on a partnership despite the lack of pretax profit.
Keywords: partnership taxation, tax credits, existence of partnership
JEL Classification: H25
Suggested Citation: Suggested Citation
Alarie, Benjamin and Xue Griffin, Bettina and Yan, Christopher, An Unprofitable Pretax Venture Can Still Be a Partnership (June 21, 2021). 171 Tax Notes Fed. 1951 (June 21, 2021), Available at SSRN: https://ssrn.com/abstract=3885911
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