Thought-provokinganalysis and opinion on federal tax issues

Monthly Archives: November 2019

Sun Capital Case Rejects Joint Economics And Favors Separate Formalities In Determining Whether A Partnership In Fact Exists

November 27, 2019

by Monte A. Jackel

The recent Sun Capital case in the First Circuit rejected the holding of the District Court below that two separate entities had formed a deemed partnership in fact due to their joint objectives, cooperation and sharing in joint profits and losses´┐╝. Rather, the First Circuit focused more heavily on the separateness of the two entities […]

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My Revised CV

November 1, 2019

by Monte A. Jackel

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