More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury ...

The Tax Court has previously held that a partner who contributes his own note to a partnership in exchange for a partnership interest takes no basis in the interest and their capital account is not ...

For federal income tax purposes an LLC, or limited liability company, is considered a disregarded entity. In effect, the LLC does not exist under the Internal Revenue Code. Despite this fact, a ...