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As with all other aspects of partnership taxation, the dual nature of a partnership for tax purposes — as at times an aggregation of its partners, and at times an entity — complicates the discussion, particularly because no one, including the author, has been able to articulate a comprehensive statement of when the aggregate, and when the entity, aspect should predominate.

Payments Other Than 736(b) Payments - 736(a) (1) Definition of 736(a) Payments (2) Tax Consequences of 736(a) Payments (a) Distributive Share of Partnership Income (b) Guaranteed Payments c.

Payments in Respect of Partnership Property - Section 736(b) (1) Definition of 736(b) Payments (2) Valuation of a Partner's Interest in Partnership Property (3) Tax Consequences of 736(b) Payments (4) Section 736(b) Payments Attributable to 751 Property (5) Section 736(b) Payments - Effects on Partnership (6) Series of 736(b) Payments b. Determination of Amount Includible in Gross Estate 1.

§§301.7701-2 and -3, recognize partnership as the default tax classification for all domestic entities that are not organized as corporations or joint stock companies, or engaged in certain regulated businesses like banking and insurance.

A number of problems have emerged, particularly for LLCs treated as disregarded entities, including a controversial decision by the IRS to treat the disregarded entity as the one responsible for payroll taxes for its employees, and questions about the status of recourse liabilities of a disregarded entity, particularly one that owns a partnership interest.

Nevertheless, Subchapter K has not been amended to recognize these changes.

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