A Complete Misinterpretation of the “Small Partnership” Exception
Date
2017-09-08
Authors
Harl, Neil
Major Professor
Advisor
Committee Member
Journal Title
Journal ISSN
Volume Title
Publisher
Authors
Research Projects
Organizational Units
Organizational Unit
Iowa State University Digital Repository
The Iowa State University Digital Repository is the open access institutional repository for the university to collect, manage, share, and preserve free, worldwide access to research and scholarship of Iowa State faculty, staff, and students.
Material in the Digital Repository covers a wide range of disciplines from engineering to social sciences to arts and humanities.
Journal Issue
Journal Issue
Is Version Of
Versions
Series
Department
Iowa State University Digital Repository
Abstract
The “small partnership” exception, enacted in 1982 as part of TEFRA,1 has been criticized in the past, mostly by the Joint Committee on Taxation, but never as irresponsibly as the recent release by the Office of Chief Counsel of the Internal Revenue Service, dated July 12, 2017 and released August 18, 2017.2 The author (or authors) write as though they had never read I.R.C. § 6231(a)(1)(B) of the Internal Revenue Code. The criticism comes less than six months before the “small partnership” exception is scheduled to be history unless an aggressive effort to save the highly important concept before the end of this year is achieved with the Congress (it is pending as HR 3508).