Monte A. Jackel, Lecturer/Principal, Jackel Tax Law, published an article in Tax Notes Federal, a weekly publication of Tax Analysts, Fairfax, VA. In this article, Jackel discusses whether nonrecognition treatment in transfers among related parties should be allowed when that same transfer creates special basis for the transferee partner without expending any new capital.

Tax Notes Federal
Date: Nov. 7, 2022
By: Monte A. Jackel
Disallow Uneconomic Partnership Special Basis

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“Instead of conceding the bona fides of the special basis adjustment…[in this case], as the IRS has apparently done, the adjustment should have been challenged as an anticipatory assignment of income or an equivalent type of item or, alternatively, as a transfer of no net equity if the facts would justify that result.

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