Tax Court rejects IRS’s position that member interests in an LLC are limited partnership interests for passive activity rule purposes under IRC §469.
DOWNLOAD ARTICLE Tax partner Ed Kaplan successfully represented the taxpayer against IRS proposed tax assessments in excess of $2,000,000 in Newell v. Commissioner, TC Memo 2010‑23. In adopting Ed’s arguments, the Tax Court rejected the Service’s long‑standing position that member interests in LLCs are to be treated solely as limited partnership interests for purposes of the passive … 더 읽기