AIM 6354-521

Partnership Tax
The University of Texas at Dallas
Summer 2006
(April 14, 2006)

Lecturer: Ronald J. Blair, CPA, MBA

Office: SOM 4.227 MTh 9:00 – 4:00
Phone: 972-883-4430 F 10:00 – 3:00
Email: rblair@utdallas.edu
Website: http://utdallas.edu/~rblair/
TA: Simon
972-883-6498
SM 4.808

Text: Lind, Schwarz, Lathrope, and Rosenberg, Fundamentals of Partnership Taxation,

Seventh Edition, Foundation Press, 2005 (ISBN 1-58778-832-2)

Discussion slides are based generally on the text. Other references include: McKee,
Nelson & Whitmire, Federal Taxation of Partnerships and Partners, Third Edition,
Warren, Gorham & Lamont

In the frequent quotation of statute in the classnotes (slides), emphases of certain words
and phrases are added by the lecturer.

Textbooks and some other bookstore materials can be ordered online through MBS
Direct Virtual Bookstore. They are also available in UTD Bookstore and Off-Campus
Books.

Course Objective
The course will include an analysis of the IRC, Treasury Regulations, and other
authorities relating to the fundamentals of taxation of partnerships. Its purpose is to give
the student knowledge of the tax implications of this organizational form of business
operation - the effect, the advantages and disadvantages, and the pitfalls, as well as the
responsibilities that go with it. It will also give the student an introduction to the
partnership return and its purpose.

Students should read the assigned chapters, IRC sections, Regs, and prepare the weekly
assigned problems. Students are strongly urged to work the problems as assigned before
solutions are accessed. This will enable you more quickly grasp the concepts involved as
you compare your solutions to the posted solution, and will prepare you for the test
problems as they will be very similar in content.

Students are encouraged to obtain a copy or print each IRC section in Subchapter
K for reference throughout the semester.

1
Communications
E-Mail: Use WebCT to communicate with the instructor or TA. This is a closed system
and only the person to whom the message is address is allowed access. Students may
address messages to the instructor or TA privately. Or messages may be addressed to
include all other students, such as to raise a question that might be of interest to everyone;
responses will be made accordingly.
Discussion: The Discussion feature can be used to post messages to other members of
the class. This is an open system and all class members can access postings on it. The
instructor and TAs do not normally respond to this feature.
Personal messages should be sent by email and not posted on the discussion board.

NOTE: You MUST have a password and login ID from UTD’s Information
Resources Department in order to access databases and electronic journals. Allow
at least 24 hours to activate your computer account.

Grading Information:
Grading: Two tests – 20 points each 40
Final exam 25
Partnership return 25
Class attendance, participation, periodic quizzes 10
Total points 100
Exams
Two tests and a final are open book, consisting generally of problems, rules, and concepts
similar to the text problems assigned, but answered in a multiple choice format.

Translation of the total point score into a letter grade will be based on the instructor’s
judgment. The letter grade will reflect each student's performance relative to the course
and standards expected of graduate students at the University of Texas at Dallas.

Scholastic Dishonesty
The University has policies and discipline procedures regarding scholastic dishonesty.
Detailed information is available on Scholastic Dishonesty web page. All students are
expected to maintain a high level of responsibility with respect to academic honesty.
Students who violate University rules on scholastic dishonesty are subject to disciplinary
penalties, including the possibility of failure in the course and/or dismissal from the
University. Since such dishonesty harms the individual, all students and the integrity of
the University, policies on scholastic dishonesty will be strictly enforced.

2
Course Schedule
Su'06
Wk Date Topic IRC §§ Regs §§
Partnership Tax in Brief
15-
1 May Chapter 1 §§701, 7701
Overview of Taxation of Partnerships and Partners
Problems: pp. 15, 16
Assembling a Partnership
Chapter 2 §§721 - 723, 704, 724
Formation of a Partnership
Problems: pp. 36, 43, 46, 50 and 51, 59, 73, 74 and 75
22-
2 May Rules of Partnership Operations - In General
Chapter 3 §§701-703, 704(d), §§1.701-1, 1.702-1(b),
705-706 1.703-1(a), 1.704-1(d)
Operations of a Partnership - General Rules
Problems: pp. 97, 100, 104, p. 107 #1 and p. 114 #1
29-
3 May Holiday
Partnership Operations - Allocations
Chapter 4,
A Introduction
4 5-Jun B Special Allocations Under §704(b)
§704(b)
Problems: p. 154 ##1 and 2; p. 165
Test 1
Chapters 1 - 3

3
 Allocations (cont'd)
Chapter 4 (cont'd)
C Allocations with Respect to Contributed Property
§704(a) and (c) §§1.701-3(a),
Problems: p. 188 ##1 and 2 1.704-1(b)(1) and (2)
D Allocation of Partnership Liabilities
§§704(c)(1)(A), §§1.752-1, 1.752-2(a) - (c)
752(a) and (c)
Problems: p. 207 #1
5 12-Jun E Allocations Where Partners Interests Vary During the Year
§703 (c)(2)(B) and (d) §1.706-1(c)(4)
Problem: p. 213 #2
F The Family Partnership Rules
§704(e) §704-1(e)(1) and (3)(i)(b)
Problems: p. 218 and 219
The Anti-Abuse Regs. - §1.701-2
Chapter 10 §§1.701-2(a) - (c),
The Partnership Anti-Abuse Regs 1.702-2(e), (h) and (I)
Problem: p. 400
Partnership Return
Form 1065 Form 1065
Form 1065 Software
6 19-Jun Assign partnership practice return - due June 26
Partnership return project - due July 10
Test II
Chapters 4 and 10
Partner / Partnership Transactions
Chapter 5 §§707(a)(1) and (c), §§1.707-1(a) and (c),
267(a)(1) - (d), 453(g) 1.707-3(a) - (d)
Transactions Between Partners and Partnerships
Problems: pp. 227 and 228; p. 233 #1; p.241 ##1 and 2; p. 247 ##1 and
2
Partnership Interest Dispositions
7 26-Jun Chapter 6 §§705(a), 706(c ), 741, §§1.7061(c)(1) - (5),
742, 743, 751(a) - (f) 1.743-1(a) - (e),
752(a), 754, 755 1.751-1(a) and (c),
1.754-1, 1.755-1(a)
Sales and Exchanges of Partnership Interests
Problems: p. 265 #1, p. 267, p. 272, and p. 281 #1
Partnership practice return due - Review and Discuss

4
 Distributions - Operating
Chapter 7 §§731, 732(a) - (d), 733, §§1.731-1(a)(1) and (3),
(Except E) 735, 751(a) - (d), 1.732-1(a) - (d),
8 3-Jul §1245 1.733-1, 1.735-1,
17.735-1, 1.1245-4(f)(2)-
(3)
Operating Distributions
Problems: p. 294 ##1 and 2; p.297 #1, p. 303, and p. 308
Liquidations / Terminations
Chapter 8 §§708(b)(1), 731, 732, §§1.731-1(a)(2), 1.731-2(b),
735, 751 1.731-1(b)(4)
Liquidating Distributions and Terminations
Problems: p. 326, p. 339 #1, p. 348, p 354, p. 360, p. 378 #1
9 10-Jul Death of a Partner
Chapter 9 §§694, 706(c ), 708(b), §§1.742-1, 1.753-1(a)
753, 1014(a) and (c ),
§2033
Consequences of Partner's Death
Problems: p. 393, p. 394 #2
Partnership return project due
S Corporations
10 17-Jul Chapter 11 §§311(b), 1361, 1362,
1363, 1366(a) - (e),
1367, 1368, 1371,
1372, 1374, 1375,
and 1378
11 24-Jul S Corporations and Their Shareholders
Problems: pp. 412, 417, p. 431 #1, p. 435 #1 and 441 #1
Partnership return project - Review and Discuss
Final
12 28-Jul Exam Emphasis on Chs. 5, 6 - 9 and 11

5
Syllabus Addendum
Each student in this course is expected to exercise independent scholarly
thought, expression and aptitude. This addendum to the course syllabus is
provided to assist you in developing and maintaining academic integrity
while seeking scholastic success.
General Comments:
• All academic exercises (including assignments, essays, laboratory experiments and reports,
examinations, etc.) require individual, independent work. Any exception(s) will be clearly
identified.
• Be sure your name or identifying number is on your paper.
• Complete and turn in academic exercises on time and in the required format (hardcopy, electronic,
etc.).
• Retain confirmation of document delivery if submitted electronically.
• Retain all research notes and drafts until the project or assignment has been graded.
• Obtain written authorization from your instructor prior to submitting a portion of academic work
previously submitted for any academic exercise. (This includes an individual or group project
submitted for another course or at another school.)
Essays and Significant Papers:
Be prepared
• To present periodic drafts of work in process
• To correctly and completely reference all sources of information using the citation format prescribed
• To turn your completed assignment in timely and in the prescribed manner (electronic, hardcopy, etc.)
Examinations:
Be prepared
• To leave all personal belonging at the front of the room or other designated location (this includes cell
phones, turned off of course, and beverage containers)
• To present your UTD Comet Card
• To remove your cap or hat
• To remove the batteries from any electronic device (e.g. calculator)
• To exchange blue books or bring them early as required
• To change seating
• To sign out when exiting the testing room
• To be escorted for lavatory use

All episodes of suspected scholastic dishonesty will be reported according to

University policy. Students who violate University rules on scholastic
dishonesty are subject to disciplinary penalties, including the possibility of
failure in the course and/or dismissal from the University. Since such
dishonesty harms the individual, all students and the University, policies on
scholastic dishonesty will be strictly enforced. Penalties that may be
assessed for scholastic dishonesty may be reviewed in Subchapter D.
Penalties at http://www.utdallas.edu/student/slife/chapter49.html