This book focuses on tax planning in the real estate context. To adequately provide tax-planning...

Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...

Peracchi v. Commissioner is a lightning rod for commentators and the bane of students of...

This article takes a critical look at the factors the income tax regulations use to...

Industry estimates indicate that, over the past several years, section 1031 qualified intermediaries have lost...

This Article presents a theory of partnership taxation. To provide context for the presentation, the...

Profits-only partnership interests grant service-providing partners an interest in the profits of a partnership but...

Economies of scale exist if long-run average costs decline as output rises. All else being...

The proper tax treatment of profits-only partnership interests is an unsolved aspect of tax law....

The tax-free treatment of like-kind exchanges presents one of tax law’s most compelling equity conundrums....

Qualified tax partnerships are arrangements that come within the definition of tax partnership but elect...

Property owners of all sizes realize that exchanging property under section 1031 presents tax-saving possibilities....

Related-party exchanges under section 1031 raise many technical, theoretical, and policy issues. Unfortunately, this topic...

Section 1031 exchanges frequently occur in proximity to business transactions (i.e., entity formations, mergers, divisions,...

This article takes a critical look at the factors the income tax regulations use to...

Qualified tax partnerships are arrangements that come within the definition of tax partnership but elect...

Line-drawing analysis finds application in every area of law. Criminal law draws a line between...

Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...

Peracchi v. Commissioner is a lightning rod for commentators and the bane of students of...

This article takes a critical look at the factors the income tax regulations use to...

Tax law classifies business arrangements as one of three general structures: (1) disregarded arrangements, (2)...

Industry estimates indicate that, over the past several years, section 1031 qualified intermediaries have lost...

Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...

This article takes a critical look at the factors the income tax regulations use to...

Economies of scale exist if long-run average costs decline as output rises. All else being...

Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...

Economies of scale exist if long-run average costs decline as output rises. All else being...

Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...

Peracchi v. Commissioner is a lightning rod for commentators and the bane of students of...

Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...

Line-drawing analysis finds application in every area of law. Criminal law draws a line between...

Economies of scale exist if long-run average costs decline as output rises. All else being...

Peracchi v. Commissioner is a lightning rod for commentators and the bane of students of...

Line-drawing analysis finds application in every area of law. Criminal law draws a line between...

This Article introduces the concept of the law school firm. The concept calls for law...

This report addresses recent suggestions by the Obama administration, lawmakers, and others that some passthrough...

Section 704(c)(2) provides an exception to the section 704(c)(1)(B) anti-mixing bowl rules. Commentators have observed...

Related-party exchanges raise the issue of improper extension of the Section 1031(a)(3) 45-day identification and...

Series limited liability companies are a fairly new form of business entity. Some observers worry...

The Ninth Circuit recently held that the non-tax-avoidance exception of Section 1031(f) generally will be...

This is the manuscript of a talk given at a public forum on tax expenditures...

Tax law allocates partnership tax items in accordance with the partners' interests in the partnership...

The economic downturn has depressed the real estate market, a significant component of the section...

Market forces in a depressed real estate market often lead to foreclosures, which may generate...

Tax law (section 1031 in particular) has spawned a new investment vehicle—open tenancies in common....

Over the last several years, reverse exchanges have become a fixture of section 1031. A...

The law governing section 1031 exchanges of personal-use residences ranges from very explicit, in the...

Studies in the theory of the firm help explain partnership attributes and the relationships partners...

This Article describes the section 1031 deferred exchange safe harbors. It describes how property owners...

This is a comprehensive treatise on section 1031 like-kind exchanges.

Property owners often acquire tenancy-in-common (TIC) interests as replacement property in section 1031 exchanges. Generally,...

Section 1031 nonrecognition applies only to exchanges of like-kind properties. Although real property generally is...

The federal definition of tax partnership determines who will be subject to partnership tax law...

Perhaps the most controversial income tax question in the real estate industry in 2004 was...

A myth persists. Many believe that section 1031 treats all real property as like kind...

This article explains the tax consquences of partnership mergers and divisions and describes planning opportunities...

Even with the Internal Revenue Service's publishing Rev. Proc. 2000-37, there is no authoritative guidance...