Semantics and Substance in Partnership Mergers

Posted: 26 Sep 2004

See all articles by Darryll K. Jones

Darryll K. Jones

Stetson University College of Law


In this report, Professor Jones argues that semantics are useful in a world in which fluency with regard to substantive partnership tax is more fantasy than reality. He uses the semantic rules applicable to partnership mergers as context. In particular, Professor Jones shows how the frequent reliance on semantics leads to an incorrect result to the extent that continuing partners in a partnership merger are incorrectly granted a nonrecognition opportunity.

Suggested Citation

Jones, Darryll K., Semantics and Substance in Partnership Mergers. Tax Notes, Vol. 104, No. 14, September 27, 2004, Available at SSRN:

Darryll K. Jones (Contact Author)

Stetson University College of Law ( email )

1401 61st Street South
Gulfport, FL 33707
United States

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