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Leveraged Partnership Fails and “Should” Opinion Did Not Prevent Penalty

August 16, 2010 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

In Canal Corp. v. Commissioner, 135 T.C. No. 9 (Aug. 5, 2010) the Tax Court ruled that a corporation in effect “sold” the business of its subsidiary when the subsidiary contributed the business assets to a partnership with another company … [Continue reading] about Leveraged Partnership Fails and “Should” Opinion Did Not Prevent Penalty

Filed Under: Partnerships, Penalties

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