The document discusses the tax implications for partnerships, particularly focusing on publicly traded partnerships and the allocation of income, gain, loss, and deduction among partners. It highlights the conditions under which a partnership is not treated as a publicly traded partnership, the importance of qualifying income, and the allocation rules under Section 704(b) and 704(c) of the Code. The document also addresses tax allocations related to contributed properties and book-tax differences.
doj/DataSet10/EFTA01384998.pdf
{"document_type":"legal","document_subtype":"tax document","reference_numbers":["Section 7704","Section 704(b)","Section 704(c)"]}