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INCOME TAX PROJECT 1 (MEETING ON TAX TREATMENT OF BROKERAGE PARTNERSHIPS, February 28, 1952)

handle is hein.ali/aliftp0395 and id is 1 raw text is: MEETING ON AX TEATMENT OF BROKERAGE PARTNERSHIPS February 28, 1952 Norris Darrell (Sullivan & Cromwell) Edwin Cohen (Hatch, Root, B3arrett, Cohen & Knapp) Charles C. Parlin (Shearman & Sterling & Wright) Nelson Adams (Davis, Polk, Wardwell, Sunderland & Kiendl) John P. Ohl (Cahill, Gordon, Zachary & Reindel) George G. Tyler (Cravath, Swaine & Moore) Robert A. McDowell ( Sullivan & Cromwell) Richard H. Appert (White and Case) William C. Warren Eugene J. Kaplan Purpose: The meeting was arranged to hear the vlews of attorneys who rep- resented and were acquainted with the problems of large brokerage partnerships on the kind of tax treatment which they felt was desirable and feasible in connection with such partnerships. The problems to be discussed were set-forth in the following agenda which was sent to the participants: 1. Contributed Property. Should the amount of money and the basis of property contributed by a partner be reflected in the basis of his partnership interest? This would result in the realization at the time .of the dissolution of the partnership or the disposal of a partnership interest of gain or loss on any pre-contribution appreciation or decrease in the value of the property. Such a result will be avoided in the case of the average partnership since gain or lose on termination of a partner's interest in believed to be undesirable. Which rule would brokerage partners prefer?