TAX 9900 Lecture Notes - Lecture 61: Payment

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21 Apr 2020
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Other transactions between a partnership and its partners. Introduction: distributive share based on allocation of partnership income pursuant to rules we"ve discussed so far, typically covers partner compensation , partner do receive payments for matters not directly related to their activity as partners of the partnership. Services in a capacity other than that as a partner. Use of capital: partner acting in capacity as a partner sec. 707(c) applies: partner acting as a third party with respect to the partnership sec. 707(a) applies: this unit also addresses tax consequences of paying a partner for services (which are not property for sec. I may not be willing to take 1%; if pship doesn"t earn $ in first year, may get loss. If i get gp under 199a, do everything to get out of gp status and get back to dis share: always ordinary to me- gp to partner always ordinary, payor- can deduct-

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