Download This PaperAn 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
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
Feedback
Feedback to SSRN
If you need immediate assistance, call 877-SSRNHelp (877 777 6435) in the United States, or +1 212 448 2500 outside of the United States, 8:30AM to 6:00PM U.S. Eastern, Monday - Friday.