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Business & farm
NO. I disagree with @Carl .
When there is a change in partnership ownership, the statute and regulations under Section 706 require that allocations are based on specific rules; an interim closing of the books or proration method.
There are rules regarding each of the allocation methods and the proration method can only be used if agreed to by all the partners. These rules are designed to avoid shifting of tax allocations.
In your case, the partners need to determine how they want to allocation the earnings based on the outcome of each of the above methods.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
Also keep in mind the date of replies, as tax law changes.
‎September 11, 2019
7:14 AM