TABLE OF CONTENTS

Chapter 1, Initial Year Return Issues

• This chapter deals with three specific types of expenses:
• Syndication Expenses
• Start Up Expenses.
• Receipt of a Capital or Profits Interest
• Payments Capitalized, Deducted, or Distributed?
• Other issues covered in this chapter include the tax implications of payments ready made to partners:
• Organizational Expenses
• IRC section 707(a) - Partner or Non-Partner
• Guaranteed Payments

Chapter 2, Capital Accounts, Basis, and Liabilities

• Partnership's basis in its assets
• Partnership liabilities
• Partner's basis in his or her partnership interest
• IRC section 754 election
• Contributions to the Partnership
• Capital accounts
• Accounting for Book/Tax differences

Chapter 3, Contributions of Property with Built-in Gain or Loss IRC section 704(c)

• The Anti-Abuse Rule
• Impact of IRC section 704(c) on the sharing of non-recourse liabilities
• IRC section 704(c) in the context or depreciable property IRC section 704(c) in the context of amortizable property
• IRC section 704(c) in the context of non-depreciable property
• Reverse" IRC section 704(c) which addresses re-valuations

Chapter 4, Distributions

• Distributions of Property to a Partner that Contributed Built-in Gain or Loss Property
• Distributions of Built-in Gain or Loss Property to a Noncontributing Partner
• Disproportionate Distributions
• Disguised Sales
• Basics - Current and Liquidating Distributions

Chapter 5, Partnership Allocations

• Substantiality
• Factors considered in crucial the partners' interests in the partnership
• Economic effect
• Allocation of tax credits
• Allocation of items ascribable to non-recourse financial obligation