Tag Archives: npa

CAN PARTNERS’ ARM’S LENGTH AGREEMENTS ON VALUATION SURVIVE IRS SCRUTINY?

In a recent Tax Court case, the IRS attempted — unsuccessfully — to supplant the fair market value agreed to by unrelated parties in a partnership transaction with its expert’s higher estimate, asserting that the taxpayer received a taxable capital interest in exchange for services provided to a partnership, not a nontaxable profits interest. If Read More…