by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
The Korn Law Firm, P.L. / Tel (239) 354-4300 An interest in a partnership is considered a capital asset. Loss upon sale of a partnership interest is therefore generally treated as a capital loss. But can the sale of a partnership interest be restructured to permit...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Under the Internal Revenue Code and specifically under Treasury Regulations Section 301.6331-1, the Internal Revenue Service has broad authority to make continuing levies and successive seizures on recurring and periodic forms of compensation. A levy on salary or...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Seeking an end-run against its recent losses in court, the Internal Revenue Service has issued temporary Treasury Regulation, Section 301.6229(c)(2)-1T. Under the new temporary Treasury Regulation, an understated amount of gross income that results from an...
by Tyler B. Korn, Esq. | Jul 27, 2009 | Articles
When a partner withdraws from a partnership, it usually does not matter to the principals whether the withdrawing partner receives compensation for his partnership interest from third parties, from the partnership, or from the remaining partners themselves. After all,...
by Tyler B. Korn, Esq. | Jul 27, 2009 | Articles
As a matter of non-tax law, it is often preferable and less cumbersome to structure the sale of a business as a stock sale rather than as a sale of assets. Stock sales, however, do not allow purchasers to benefit from a “step up” in the basis of the acquired company’s...
