Preface

• Pages: 5-6
• Author: James R. Repetti,William H. Lyons,Charlene D. Luke

v

PREFACE

This book attempts the simplest possible introduction to an

intricate body of law. Any “simplified” description of the rules of

partnership taxation would be so misleading as to be useless. We

have therefore tried to make the subject accessible not by

paraphrasing the rules, but by including numerous illustrations that

are as straightforward as possible. The text focuses on simple

partnerships (including where appropriate limited liability

companies (LLCs) taxed as partnerships) holding few assets and

engaging in routine transactions. It places the rules in context by

pointing out the pu rposes of the st atute and regu lations and

presenting background in formation about practical matters such as

how partnerships maintain capital accounts and how nonrecourse

financing works. Using many e xamples, it then shows the operation

of the rules in everyday cases encountered by practitioners.

This is not a reference book: many interesting and difficult

issues have been ignored. Some matters, such as the application of

§ 736 to noncash distributions and the taxation of tiered

partnerships, are not discussed at all. Most of the points that are

addressed, however, are discussed at considerable length. Our goal

has been to give students background material and illustrations so

that they can begin to understand and work with a statute that was

drafted for (and by) experienced practitioners and so that they can be

prepared to make sense of any future changes.

Most chapters end with a section comparing the tax treatment

of partners with that of the shareholders of S corporations. Many

students enco untering partnershi p taxation for the first time have

already studied subchapter S. We expect that an examination of

some of the basic differences between subchapters S and K should

help those students understand both subjects. The book is current

through December 31, 2022.

We thank our previous coauthor, Alan Gunn, for all of his

contributions to this book. We greatly benefitted from Alan’s

invaluable insights about partne rship taxation and his good humor.

He is a masterful teache r to whom we owe much. We also thank

James E. Tierney and Larry D. Ward for helpful comments on

previous editions. In addition, we thank Reid Diaz, Boston College

Law School Class of 202 2, for helpful research assistance. Lastly,

James Repetti gratefully acknowledges support provided by the

Paulus Endowment for Tax.