Index

• Pages: 305-316
• Author: James R. Repetti,William H. Lyons,Charlene D. Luke

305

INDEX

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References are to Pages

ACCOUNTS AND ACCOUNTING

Accrual method, 30

Calendar year, use of, 30

Capital Accounts, this index

Cash method used by transferor of

going business, 169

Drawing accounts, 81

Entity approach, 29

Income accounts, 81

Timing of partnership income, 29–30

Varying ownership interests, cash

method accounting, 114

AGGREGATE APPROACH TO

TAXATION

Generally, 2–4

ALLOCATION OF TAX ITEMS

Generally, 75–108

Anti-abuse rules, 139–141

Assignment of Income, this index

Basis adjustments under Section

734(b), 273–277

Book value. Contributed property,

below

Built-in gain or loss, property with.

Contributed property, below

Capital Accounts, this index

Ceiling rule, 125–130

Code and regulatory overview, 75–76

Contributed property, allocations

attributable to

Generally, 123–152

Anti-abuse rules, 139–141

Book value and tax basis,

difference between

Depreciable property

with built-in gain,

130–131

Mixing bowl rules, 149–

150

Non-depreciable property

with built-in gain,

124

Ceiling rule, 125–130

Depreciable property with

built-in gain

Generally, 130–141

Anti-abuse rules, 139–

141

Book value and tax basis,

difference between,

130–131

Comparing methods,

138–139

Remedial allocation

method, 135–138

Traditional method, 131–

134

Traditional method with

curative allocations,

134–135

Distributions and book/basis

disparity (mixing bowl

rules), 149–150

Interaction of Sections 704(c)

and 737 with Section

199A, 150–151

Non-depreciable property with

built-in gain

Generally, 124–130

Book value and tax basis,

difference between,

124

Ceiling rule and

traditional method,

125–127

Ceiling rule distortions,

remediating, 127–

130

Notional tax items, 129–

130

Remedial method, 129–

130

Taxable gain and loss,

limits on amount

allocated, 125–127

Traditional method with

curative allocations,

127–129

Property with built-in loss

Generally, 141–143

Basis adjustment, 142–

143

Built-in loss, defined, 141

Proposed regulations,

141–142

Statutory limitation, 141

Reverse Section 704(c)

allocations under Section

704(b)

Generally, 143–148

Alternative to

revaluation, 145