The U.S. Tax Court has held in ES NPA Holding, T.C. Memo 2023–55, that an interest in a partnership granted for services was a profits interest that was not taxable to the taxpayer under Revenue Procedure 93–27.

(This article is reprinted from a letter to the editor of Tax Notes Federal published on May 8, 2023)

I am writing today to state some general observations relating to my recent article on partnership aggregate and entity issues.1 What prompted me to write this…