The Colorado Lawyer
46, number 5
This article endeavors to help practitioners who are not partnership tax allocation experts identify when they should consult with those with that expertise. The partnership-allocation Treasury Regulations have been called "a creation of prodigious complexity ... essentially impenetrable to all but those with the time, talent, and determination to become thoroughly prepared experts on the subject." This article is written for those, to date at least, without that time and determination. At the same time, the article provides an introduction to the partnership tax allocation rules for those contemplating making the requisite investment of time and determination.
The term "partnership," for purposes of this article, means a tax partnership. A tax partnership typically includes state law partnerships and limited liability companies (LLCs) with two or more members. The term "partner" may also refer to an LLC member.
Regarding tax law generally, there is almost no rule without an exception. Accordingly, half the sentences in this article could begin with the words "typically" or "generally"; generally, they don't.
Walter Schwidetzky, Partnership Tax Allocations: The Basics, Colo. Law., May 2017, at 39.