Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more
“Disposing” of a Partnership Interest- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer his adjusted basis for the interest – i.e.,...more
Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more
Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more