The employee retention credit is among those prohibited under the section for taxpayers trafficking in federally controlled substances, the Tax Court held, finding against a marijuana dispensary business.
A member’s death will likely require apportioning LLC income and may entail treatment of the interest as a sale or disposition or even terminate the LLC.
Payments including for electricity from electric vehicle stations applied toward the real estate investment trust’s qualifying gross-income tests under Sec. 856, the Service ruled.
In Soroban Capital Partners, the Tax Court analyzed the roles, responsibilities, and capital contributions of three limited partners in a limited partnership and determined that they were limited partners in name only.