Jackeltaxlaw

Excerpted from Tax Notes.

I read with interest the news story on an IRS announcement declaring the agency’s intention to audit many more “complex partnerships” in the near future.1 The headline for the…

Adapted from a book review published in Tax Notes Federal on August 28, 2023. A freely available link not behind Tax Analysts paywall is available on LinkedIn.

Monte A. Jackel is an adjunct professor of…

Adapted from a letter to the editor of Tax Notes on Aug. 7, 2023

Last week, the General Accounting Office issued a report describing the poor audit performance of the IRS in the auditing of what are referred to in the report as “large partnerships”…

Based in part in a letter to the editor of Tax Notes on July 10, 2023.

On June 26, 2023, the U.S. Supreme Court granted certiorari in Moore,1 a case from the U.S. Court of Appeals for the Ninth…

Proposed regulations were filed with the Federal Register on June 14 under IRC section 6418. See REG-101610–23.

(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…

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.

(For a parallel analysis of these issues in my latest letter to the editor of Tax Notes Federal, see my letter to the editor, here).