Economic Substance, Promissory Notes and Partnerships

We look at a case where the IRS failed in an attempt to argue that a transaction had no economic substance or otherwise failed under the anti-abuse partnership regulations.  The case is Countryside Limited Partnership v. Commissioner, TC Memo 2008-3 where the taxpayers used the partnership distribution rules to allow two partners to have their interests in the partnership liquidated with no tax cost just prior to the partnership selling a significant asset at a gain.The materials are located at http://www.edzollars.com/2008-01-14_Partnership.pdf .The podcast is sponsored by Leimberg Information Services, on the web at http://www.leimbergservices.com .