•Issued under sec. 701•Designed to provide IRS a basis for attacking abusiveuse of partnerships.•Incorporate "common law concepts" such asstep transaction, business purposes, etc.,•Not exclusive•Do not pre-empt those doctrines.•Apply only to the income tax, not estate and gift tax.•Not intended to apply to bona fide business arrangements.•Controversy over IRS power to issue these regs.
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Taxation in the United States, 1920, 1922, 1916, 1918, 1925