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SUBCHAPTER K [i] (COUNCIL DRAFT 9, November 24, 1981)

handle is hein.ali/aliftp0365 and id is 1 raw text is: THIS DRAFT IS PRIVATE AND CONFIDENTIAL
PUBLIC DISCLOSURE IS PROHIBITED*
(Not to be sold. offered for sale. or otherwise published)
The American Law Institute
FEDERAL INCOME TAX PROJECT
Council Draft No. 9
Subjects Covered:
SUBCHAPTER K
Part Q. Partnership Liabilities
Part R. Measuring a Percentage Interest in Partnership Capital and Profits
Part S. Distinguishing Contributions and Distributions from Sales
Part T. Motive for Partnership Transactions
Part U. Elections
Part V. -Status-.
Part W. Activities
Part X. Sales and Acquisitions of Partnership Interests - Some Further Points
Part Y. Tiered Partnerships
Part Z. General Rules for Applying Code Provisions to Partnerships
Submitted to the Meeting of the Council of the American Law Institute on
December 9 (at 10:00 a.m.), 10, 11, and 12, 1981 at The Association of the Bar
of the City of New York. 42 W. 44th Street. New York City. This draft is
scheduled for discussion on Friday, December 11. at 2:00 p.m.
November 24, 1981
The Executive Office
THE AMERICAN LAW INSTITUTE
4025 Chestnut Street
Philadelphia. PA 19104
'This is a preliminary draft submitted on a private and confidential basis to a limited irollp for the sole
puipose of study and criticism. It has not been promulgated or approved by the Council or the
members of The American Law Institute.
As an unpublished document intended for internal use. this draft should not be generally circulated or
distributed, nor should it be quoted from or cited or its substance disclosed in any public address or
writing.