Friday, February 3, 2006
The IRS has issued Notice 2006-14, 2006-8 I.R.B. ___ (Feb. 21, 2006):
The Treasury Department and the IRS are conducting a study of the current § 751(b) regulations and are considering alternative approaches to achieving the purpose of the statute. In this regard, comments are requested on the approaches discussed in this Notice, as well as other possible approaches to determining a partner’s share of hot assets and to prescribing the tax consequences of a disproportionate distribution.