The IRS will not acquiesce to Tax Court decisions allowing general partners who guaranteed the debt of their partnership and were not in bankruptcy in their individual capacity to exclude from gross income cancellation-of-debt (COD) income arising from a Title 11 bankruptcy proceeding of the partnership.
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Partnership & LLC taxation
Transfers of installment obligations would trigger gain or loss under proposed rules
The IRS issued proposed regulations that govern the tax treatment of transfers of installment obligations in exchange for equity interests in corporations or partnerships.
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