Paul L. Caron
Dean
Pepperdine Caruso
School of Law
COD
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Lesson From The Tax Court: The DOI Downside To Disregarded LLC
According to this Wikipedia entry, the “limited liability company ("LLC") has grown to become one of the most prevalent business forms in the United States.” That is likely because state law gives substantial liability protections to LLCs, similar to traditional corporations, but allows for more flexible ownership and governance structures. That flexibility also creates more
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Lesson From The Tax Court: Tax Consequence For Discharge Of Non-Recourse Debt
One of the hard concepts to teach students is the different tax treatments for recourse loans and non-recourse loans. It gets especially confusing when the sale of underwater property includes a Discharge of Indebtedness (DOI) as part of the sale. In Michael G. Parker and Julie A. Parker v. Commissioner, T.C. Memo. 2023-104 (Aug. 10,
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Lesson From The Tax Court: Tax Consequence For Discharge Of Non-Recourse Debt
One of the hard concepts to teach students is the different tax treatments for recourse loans and non-recourse loans. It gets especially confusing when the sale of underwater property includes a Discharge of Indebtedness (DOI) as part of the sale. In Michael G. Parker and Julie A. Parker v. Commissioner, T.C. Memo. 2023-104 (Aug. 10,
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Lesson From The Tax Court: How To Calculate Insolvency For The §108 Exclusion
While not as certain as death and taxes, small businesses failures are highly probable events. This webpage from the Bureau of Labor Statistics goes into the gnarly. When a small business fails, that often means it cannot repay loans. A lender will often write off the loan as a bad debt, discharging the borrower from
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Lesson From The Tax Court: How To Calculate Insolvency For The §108 Exclusion
While not as certain as death and taxes, small businesses failures are highly probable events. This webpage from the Bureau of Labor Statistics goes into the gnarly. When a small business fails, that often means it cannot repay loans. A lender will often write off the loan as a bad debt, discharging the borrower from