An Unprofitable Pretax Venture Can Still Be a Partnership

171 Tax Notes Fed. 1951 (June 21, 2021)

6 Pages Posted: 15 Jul 2021

See all articles by Benjamin Alarie

Benjamin Alarie

University of Toronto - Faculty of Law; Vector Institute for Artificial Intelligence

Bettina Xue Griffin

BLUE J LEGAL

Christopher Yan

Blue J Legal

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

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

Benjamin Alarie (Contact Author)

University of Toronto - Faculty of Law ( email )

Jackman Law Building
78 Queen's Park
Toronto, Ontario M5S 2C5
Canada
416-946-8205 (Phone)
416-978-7899 (Fax)

HOME PAGE: http://www.benjaminalarie.com

Vector Institute for Artificial Intelligence ( email )

Bettina Xue Griffin

BLUE J LEGAL ( email )

325 FRONT ST W
TORONTO, ON M8Z2C3
Canada

HOME PAGE: http://HTTP://WWW.BLUEJ.COM

Christopher Yan

Blue J Legal ( email )

325 FRONT ST W
TORONTO, ON M8Z2C3
Canada

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