Most practitioners deal with Form 1065, U.S. Return of Partnership Income, on a regular basis. This program addresses distributions, including recognition of gain, distributions of property and securities treated as money, loss on distribution, sales of contributed property, distributions of property to a contributing or noncontributing partner, liquidating distributions, allocation of basis increases or decreases, the special basis adjustment under IRC §732(d), disproportionate distributions, and mandatory basis adjustments. This program includes expert analysis by Ian J. Redpath, JD, LLM, and Michael J. Tucker, LLM, CPA, on audio and video.

Use of Materials

Audio or DVD
The user should begin by watching the DVD segment or listening to the audio CD for the chapter before reading the text. The user may wish to make notes of the most important concepts and any terms that are new. Next, the user should review the learning objectives at the beginning of the chapter and read the chapter. The user should work through each of the examples. It may be helpful to highlight important material and/or to make additional notes. Next, the user should complete the study questions at the end of the chapter and review the answers. If the user answers a study question incorrectly, s/he should review the section of the text that is indicated at the end of the explanation to the study question to assure comprehension of the material. The user should review the learning objectives once more to consider achievement of the objectives. After the user has finished watching the DVD or listening to the audio CDs and reading the text and working through the study questions, s/he may wish to review her/his notes and any sections of the text or DVD or audio CDs that were difficult. When the user is ready, s/he should complete the quizzer. Reviewing notes periodically will increase retention of the material.

Online
The user should begin by watching the streamed video segment, if any, or listening to the streamed audio segment, if any, for the chapter before reading the text. The user may wish to make notes of the most important concepts and any terms that are new. Next, the user should review the learning objectives at the beginning of the chapter and read the chapter. The user should work through each of the examples. After the user has studied each chapter, s/he should click on the link at the left to complete the interactive study questions. If the user answers a study question incorrectly, s/he should review the section of the text that is indicated at the end of the explanation to the study question to assure comprehension of the material. The user should review the learning objectives once more to consider achievement of the objectives. After the user has finished watching the streamed video, if any, or listening to the streamed audio, if any, and reading the text and working through the study questions, s/he may wish to review her/his notes and any sections of the text or video/audio, if any, that were difficult. When the user is ready, s/he should click on the link to the left to complete the quizzer. The user's CPE certificate will be provided immediately upon successful completion of the quizzer.

Chapter 1 reviews the differences between liquidating and current distributions, the methods of receiving a current distribution, and recognition of gain by a partner upon distributions of money and marketable securities treated as money and property other than marketable securities treated as money.

Chapter 2 addresses property distributions, distributions consisting of multiple assets, and the tax treatment of distributions of marketable securities treated as money.

Chapter 3 takes a look at recognition of loss on a partnership distribution, the timing of partnership distributions, the effect a distribution has on determining the partner's distributive share of partnership income or loss, and the treatment of money or property withdrawn in anticipation of current year's earnings.

Chapter 4 examines IRC §704(c)(1)(A) regarding sales of contributed property, IRC §704(c)(1)(B) concerning distributions of contributed property to a noncontributing partner, IRC §737 regarding distributions to partners who contributed appreciated property, net precontribution gain, and how to determine a partner's basis for distributed property.

Chapter 5 explores the basis and holding period of property distributed in a complete liquidation of a partnership interest, the allocation of basis rules used when the basis of property received is the adjusted basis of the partner's interest in the partnership, and the rules for allocating a basis increase or decrease.

Chapter 6 considers when a partner may choose a special basis adjustment under IRC §732(d) that adjusts the basis of certain property received in a distribution as well as the times when the adjustment is mandatory.

Chapter 7 discusses special considerations of distributions including liquidating distributions, liquidating distributions containing IRC §751 assets, and the circumstances under which a partner may a have capital loss on a complete liquidation. It also discusses IRC §751(b)-disproportionate distributions, and the mandatory basis reduction rules under IRC §743(b).

Throughout this program, the user will find explanations and discussions regarding some of the issues that often face practitioners. In order to enhance the user's comprehension of the material and highlight important practical considerations, this program includes the following designations:

A Biskalert is intended to warn the practitioner of a particular situation that may require action or other consideration by the taxpayer or the practitioner on behalf of the taxpayer.

A Biskpoint presents analysis or commentary that attempts to explain or clarify statutory or regulatory authority or decisions by the judiciary.

A Bisktip provide practical advice that may be used to help improve client service or service to the practitioner's organization.

• Describe the effects of a liquidating distribution on a partnership interest

• Apply a basis decrease formula to a partnership distribution consisting of multiple assets

• Discuss the requirements for recognizing a loss on a partnership distribution

• Explain the analysis of more complex situations where appreciated property is distributed to noncontributing partners within seven years of contribution

• Determine the holding period for property received in a complete liquidation of a partnership interest

• Explain the requirements for choosing a special basis adjustment for property distributed by the partnership

• Describe a liquidating distribution

Ian J. Redpath, JD, LLM, is a nationally recognized tax attorney and consultant from Buffalo, New York. He is a principal in the Redpath Law Offices in Buffalo and New York City where he specializes in tax litigation matters. Mr. Redpath has published numerous articles on contemporary tax issues and co-authored several books. He has extensive national and international experience in developing, writing, and presenting professional CPE programs. Mr. Redpath holds a Bachelor's degree from Hillsdale College, a JD from the University of Detroit, and an LLM (tax emphasis) from the University of Wisconsin. In addition to his active tax practice, he serves as an Associate Professor of Taxation at Canisius College in Buffalo. (Contributing Author/Speaker)

Michael J. Tucker, LLM, CPA, is a consultant with the accounting firm of T.M. Byxbee Company, P.C., in Hamden, Connecticut. In his practice, Mr. Tucker handles a wide variety of client transactions, including mergers and acquisitions, entity formations and dissolutions, and distributions to owners/shareholders/partners. He is also a Professor of Accounting at Quinnipiac University in Hamden, Connecticut. Author of over 100 articles and books dealing with various tax topics, Mr. Tucker is a frequent lecturer at conferences and seminars throughout the country. Recently, Mr. Tucker has expanded his practice and lecturing to include topics related to the workplace, including sexual harassment and employer/employee relations. He holds an LLM in Taxation from Georgetown University Law Center, a Juris Doctorate from New York University School of Law, a PhD in Accounting from University of Houston, and an MBA from New York University. (Contributing Author/Speaker)