06.23.11
Passthrough Entities – Advanced Issues – Corvallis, Oregon (June 23, 2011)
The following is information presented in the Passthrough Entities course given on June 23, 2011 in Corvallis, Oregon.
- Overhead Slides – from today’s presentation
- Partnership – Audit Technique Guide – IRS guide last revised in August 2008
- Norwood v. Commissioner, TC Memo 2000-84
- IRS FAQ on Unified Partnership Audits – Chief Counsel Notice issued August 21, 2009
- Garnett v. Commissioner, 132 TC No. 19, LLC members aren’t automatically passive (LLC member not the same as limited partner)
- Suzanne J. Pierre v. Commissioner– Check the box does not apply to single member LLC for gift tax valuation
