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Give Them My Regards: A Proposal for Applying the COD Rules to Disregarded Entities

Posted: 18 Apr 2005  

Stephanie R. Hoffer

Ohio State University (OSU) - Michael E. Moritz College of Law

Abstract

This article discusses application of the COD rules to disregarded entities and concludes that the IRS should regard disregarded entities for that purpose. Hoffer argues that to do otherwise would not only engender uncertainty in lending transactions with single-member LLCs but would also distort the federal tax system's comprehension of underlying state law business arrangements.

Suggested Citation

Hoffer, Stephanie R., Give Them My Regards: A Proposal for Applying the COD Rules to Disregarded Entities. Tax Notes, Vol. 107, No. 3, April 18, 2005. Available at SSRN: https://ssrn.com/abstract=706222

Stephanie R. Hoffer (Contact Author)

Ohio State University (OSU) - Michael E. Moritz College of Law ( email )

55 West 12th Avenue
Columbus, OH 43210
United States

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