Articles
Passive Losses, LLCs and LLPs—Two Courts Reject the Service's Attempt to Limit Losses
Published in the Journal of Taxation, Co-Authored by Richard M. Lipton
October 2009
This article analyzes the characterization of members of LLCs and partners in LLPs as "limited partners" or "not limited partners" under the passive activity rules of Section 469, in light of the applicable Regulations and recent judicial developments.