Tax News

CCH (cch.taxgroup.com) reports:

  The IRS announced that it will issue guidance under the Industry Issue Resolution (IIR) program regarding technical terminations of a publicly traded partnership (PTP) that result in multiple short tax years within one calendar year. These terminations occur when more than 50 percent of a PTP's capital and profits interest are sold or exchanged within a 12-month period (Code Sec. 708(b)) and result in the PTP having to file a Form 1065, U.S. Partnership Return of Income, for each short tax year. Taxpayers that follow this released guidance will be able ton avoid audits triggered by problems arising from the PTP's filing requirements.

  Business associations and taxpayers may submit business tax issues that they believe could be resolved through the IIR program at any time. IIR project selection criteria and submission procedures are outlined in Rev. Proc. 2003-36, 2003-1 CB 859. The IRS reviews submissions at least semi-annually, with the last review conducted for submissions received by Aug. 31, 2008.

IR-2008-110,
2008FED ¶46,581

Other References:

 
Code Sec. 708

  CCH Reference - 2008FED ¶25,202.03

 
Code Sec. 7704

  CCH Reference - 2008FED ¶43,182.01

 
Code Sec. 7804

  CCH Reference - 2008FED ¶43,266.3097

  Tax Research Consultant

  CCH Reference - TRC IRS: 12,384
CCH Reference -
TRC PART: 51,100
CCH Reference -
TRC PART: 3,250