LAST CHANCE: Who Will Be The Next FlyerTalk Member To Fly Free To Amsterdam?
Nov 7, 2008 | 3:37 pm
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A relieved captain snacks around its supervised thrust.
Nov 7, 2008 | 3:37 pm
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LEBL = BCN
Nov 7, 2008 | 3:37 pm
FlyerTalk Evangelist
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Agency is very important, especially on the bar exam.
Nov 7, 2008 | 3:37 pm
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22959 737-3B7 VivaAeroBus 09/08/1985 XA-VIY Active
Nov 7, 2008 | 3:37 pm
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Nov 7, 2008 | 3:37 pm
FlyerTalk Evangelist
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If we all worked together, I'm pretty sure we could cover all of Webster's unabridged by next Thursday... to ensure every word in the English language is in this thread...
Nov 7, 2008 | 3:38 pm
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Just realized that my last post was 8,750.
Nov 7, 2008 | 3:38 pm
FlyerTalk Evangelist
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Just kidding more 732s
22961 737-201 Aviacsa 23/08/1983 XA-TXF Active
22961 737-201 Aviacsa 23/08/1983 XA-TXF Active
Nov 7, 2008 | 3:38 pm
Join Date: Mar 2006
Location: Bay Area
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The literature complains on top of a bag.
Nov 7, 2008 | 3:38 pm
FlyerTalk Evangelist
Join Date: Feb 2006
Location: A festering pit; a pustule of a fistula set athwart the miasmic swamps of the armpit of the Gulf of Mexico - a Godforsaken wart upon a dark crevasse of the World. (IAH)
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709. Treatment of organization and syndication fees
How Current is This?
(a) General rule
Except as provided in subsection (b), no deduction shall be allowed under this chapter to the partnership or to any partner for any amounts paid or incurred to organize a partnership or to promote the sale of (or to sell) an interest in such partnership.
(b) Deduction of organization fees
(1) Allowance of deduction
If a partnership elects the application of this subsection (in accordance with regulations prescribed by the Secretary) with respect to any organizational expenses
(A) the partnership shall be allowed a deduction for the taxable year in which the partnership begins business in an amount equal to the lesser of
(i) the amount of organizational expenses with respect to the partnership, or
(ii) $5,000, reduced (but not below zero) by the amount by which such organizational expenses exceed $50,000, and
(B) the remainder of such organizational expenses shall be allowed as a deduction ratably over the 180-month period beginning with the month in which the partnership begins business.
(2) Dispositions before close of amortization period
In any case in which a partnership is liquidated before the end of the period to which paragraph (1)(B) applies, any deferred expenses attributable to the partnership which were not allowed as a deduction by reason of this section may be deducted to the extent allowable under section 165.
(3) Organizational expenses defined
The organizational expenses to which paragraph (1) applies, are expenditures which
(A) are incident to the creation of the partnership;
(B) are chargeable to capital account; and
(C) are of a character which, if expended incident to the creation of a partnership having an ascertainable life, would be amortized over such life.
How Current is This?
(a) General rule
Except as provided in subsection (b), no deduction shall be allowed under this chapter to the partnership or to any partner for any amounts paid or incurred to organize a partnership or to promote the sale of (or to sell) an interest in such partnership.
(b) Deduction of organization fees
(1) Allowance of deduction
If a partnership elects the application of this subsection (in accordance with regulations prescribed by the Secretary) with respect to any organizational expenses
(A) the partnership shall be allowed a deduction for the taxable year in which the partnership begins business in an amount equal to the lesser of
(i) the amount of organizational expenses with respect to the partnership, or
(ii) $5,000, reduced (but not below zero) by the amount by which such organizational expenses exceed $50,000, and
(B) the remainder of such organizational expenses shall be allowed as a deduction ratably over the 180-month period beginning with the month in which the partnership begins business.
(2) Dispositions before close of amortization period
In any case in which a partnership is liquidated before the end of the period to which paragraph (1)(B) applies, any deferred expenses attributable to the partnership which were not allowed as a deduction by reason of this section may be deducted to the extent allowable under section 165.
(3) Organizational expenses defined
The organizational expenses to which paragraph (1) applies, are expenditures which
(A) are incident to the creation of the partnership;
(B) are chargeable to capital account; and
(C) are of a character which, if expended incident to the creation of a partnership having an ascertainable life, would be amortized over such life.
Nov 7, 2008 | 3:38 pm
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^
Nov 7, 2008 | 3:38 pm
FlyerTalk Evangelist
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Rest is overrated.
Nov 7, 2008 | 3:38 pm
FlyerTalk Evangelist
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22962 737-201 US Airways 08/09/1983 N265AU Stored
Nov 7, 2008 | 3:38 pm
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PANC = ANC
Nov 7, 2008 | 3:38 pm
FlyerTalk Evangelist
Join Date: Feb 2006
Location: A festering pit; a pustule of a fistula set athwart the miasmic swamps of the armpit of the Gulf of Mexico - a Godforsaken wart upon a dark crevasse of the World. (IAH)
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A Biggie!
721. Nonrecognition of gain or loss on contribution
How Current is This?
(a) General rule
No gain or loss shall be recognized to a partnership or to any of its partners in the case of a contribution of property to the partnership in exchange for an interest in the partnership.
(b) Special rule
Subsection (a) shall not apply to gain realized on a transfer of property to a partnership which would be treated as an investment company (within the meaning of section 351) if the partnership were incorporated.
(c) Regulations relating to certain transfers to partnerships
The Secretary may provide by regulations that subsection (a) shall not apply to gain realized on the transfer of property to a partnership if such gain, when recognized, will be includible in the gross income of a person other than a United States person.
(d) Transfers of intangibles
For regulatory authority to treat intangibles transferred to a partnership as sold, see section 367 (d)(3).
How Current is This?
(a) General rule
No gain or loss shall be recognized to a partnership or to any of its partners in the case of a contribution of property to the partnership in exchange for an interest in the partnership.
(b) Special rule
Subsection (a) shall not apply to gain realized on a transfer of property to a partnership which would be treated as an investment company (within the meaning of section 351) if the partnership were incorporated.
(c) Regulations relating to certain transfers to partnerships
The Secretary may provide by regulations that subsection (a) shall not apply to gain realized on the transfer of property to a partnership if such gain, when recognized, will be includible in the gross income of a person other than a United States person.
(d) Transfers of intangibles
For regulatory authority to treat intangibles transferred to a partnership as sold, see section 367 (d)(3).