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Sunday, August 10, 2008

Collapsible Real Estate Partnership Proposal

by taxnick on August 10, 2008

Professor Burke proposes extending the look-through rules of under § 1(h)(9) to partnership distributions as well as sales of partnership interests to prevent conversion of unrecaptured § 1250 gain and potentially indefinite deferral.
The proposal addresses flaws in the distribution rules as illustrated by Countryside Limited Partnership v. United States allowing tax-free treatment of a distribution [...]

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A proposed student loan repayment program for law school graduates who commit to service as state or local prosecutors, or state, local or federal public defenders, now awaits President Bush’s signature. The program is contained in the Higher Education Opportunity Act (H.R. 4137), which updates existing programs and creates new ways to make higher education [...]

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