For many years the IRS has argued for a broad reading of the term “partnership item”, items that demand entity-level determinations. In the Journal of Passthrough Entities, columnist Thomas Greenaway analyzes the recent case of Alpha I, L.P., a case where the Court of Federal Claims rejected an IRS attempted broad-reaching interpretation of the term “partnership item” in a TEFRA proceeding (Tax Equity and Fiscal Responsibility Act, provisions of which are found in Code Secs. 6221 through 6233). The holding for the taxpayer in this case may signal a need for a revision of the IRS’s approach in these types of cases.
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This story is from the CCH’s monthly Focus on Tax newsletter, which provides advise and guidance on federal and state tax issues for tax and accounting professionals.
Read this article from CCH’s Journal of Taxation of Financial Products