Hell of a Town

Ask most New Yorkers what New York City has in abundance and you’ll get responses that are as varied as the personalities to whom the question is put. Museums, restaurants, performing arts, college students,[i] office buildings, street food, subway lines, cabs, dog walkers, rats, and politicians are sure to make

One of the thorniest tasks to confront a tax adviser may be having to determine whether the business or investment relationship between two taxpayers constitutes a partnership for tax purposes.

Where the persons involved have formed a limited liability company or a limited partnership under state law, they have formed a tax law partnership[i]

What is It?
It is a frequently recurring issue for those who advise the owners of rental real property, but one that is rarely raised by the owners themselves: does the ownership arrangement constitute a partnership for income tax purposes?

The question appears to be fairly straightforward – just ask any client. “We haven’t executed