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Tax Lawyer, Vol. 57, No. 1 EXCULPATORY LIABILITIES 33 33 EXCULPATORY LIABILITIES AND PARTNERSHIP NONRECOURSE ALLOCATIONS Karen C. Burke* I. INTRODUCTION The rise of limited liability companies (LLCs) classified as partnerships for federal income tax purposes challenges traditional assumptions concerning the treatment of recourse and nonrecourse liabilities under Subchapter K.1 The complle rules of sections 704(b) and 752 give little attention to liabilities that are recourse to the entity under...

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