Current developments in partners and partnerships
- Court cases decided during the reviewed period dealt with issues under the former unified audit rules of the Tax Equity and Fiscal Responsibility Act (TEFRA) that included the statute of limitation and whether an item of income or deduction was properly determined as a partner or partnership item. Other issues addressed included the economic substance of partnership transactions and debt vs. equity characterizations.
- A number of court cases dealt with the “protected in perpetuity” and substantiation requirements and other issues regarding the validity of taxpayers’ claimed deductions for charitable contributions of conservation easements.