The Worthlessness Deduction for Partnership Interests: An Unguided Missile

Authors

• Walter D. Schwidetzky, University of Baltimore School of LawFollow

Document Type

Article

Journal Title

Tax Notes Federal

Volume

183

First Page

461

Publication Date

4-15-2024

Abstract

In this report, Schwidetzky explains how a disjuncture between the provisions governing capital loss treatment and those governing ordinary loss treatment has created tax planning opportunities for a partner taking a worthlessness deduction for a partnership interest. Schwidetzky argues that some of these tax planning opportunities are inappropriate, and he proposes a simple way to fix the problem.

Recommended Citation

Schwidetzky, Walter D., "The Worthlessness Deduction for Partnership Interests: An Unguided Missile" (2024). Articles. 47.
https://scholarworks.law.ubalt.edu/fac_articles/47