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TAXATION OF PASS-THROUGH ENTITIES [i] (MEMORANDUM NO. 1, October 12, 1995)

handle is hein.ali/aliftp0481 and id is 1 raw text is: This document, as of the date it was printed, had not been considered by the Council or
membership of The American Law Institute, and therefore does not represent the
position of the Institute on any of the issues with which it deals.

The American Law Institute
FEDERAL INCOME TAX PROJECT
TAXATION OF PASS-ThROUGH ENTITIES
Memorandum No. 1
(October 12, 1995)

Subjects Covered:
I. Background
II. Classification as a Pass-Through Entity
III. Taxation of Pass-Through Entities
Appendix. The Historical Background Behind
the Section 7701 Regulations
Submitted to the Consultants for consideration at their meeting on
November 2 (at 10:00 a.m.) and 3, 1995, at
the offices of Sullivan & Cromwell, 125 Broad Street, New York, New York

THE EXECUTIVE OFFICE
THE AMEJUCAN LAW INSTITUTE
4025 Chestnut Street
Philadelphia, PA 19104-3099