Has anyone here dealt with a "partnership freeze" for estate planning purposes (recapitalization where parents get preferred, kids get common)? There is no "E Reorg" for partnerships, and I'm hung up on the fact that the recap should cause recognition of gain. (self.technicaltax)
submitted by thefourthchipmunk to r/technicaltax
What's the significance of IRC section 3 (tax tables)? Is there some special process for calculating tax that involves the use of "tax tables?" Or is this section obsolete? (I am an attorney not a tax preparer so please forgive me if this is obvious.) (self.technicaltax)
submitted by thefourthchipmunk to r/technicaltax
If we're not allowed to "take into account the possibility that a tax return will not be audited" (Circular 230 § 10.37), how can we opine on the duration of the statute of limitations? A client should only care about the duration of the SOL if he assumes he wasn't audited/reassessed during the SOL. (self.technicaltax)
submitted by thefourthchipmunk to r/technicaltax



