Reference no: EM132859556

Taxing Partnership Operation Partnership Taxable Years Code References: §§ 444(a)-444(c) and 706(b)

Regulations: §§ 1.706-1T(a), 1.706-1T(b), 1.706-1T(d), 1.442-1 (b)(1 ), and 1.442-1(b)(2)

1. The Law Firm is a newly formed partnership with 25 equal lawyer partners. Each partner has a four percent interest in capital and profits. All partners are calendar year taxpayers. Assume that all partners are on the same fiscal year (a non calendar year). May the partnership adopt that fiscal year?

2. A has a fiscal year ending in October. B has a fiscal year ending in October. C has a calendar year. They form the ABC partnership with the following in-terests in capital and profits: A and B each have 48 percent, C has four percent. What is the partnership's taxable year? The partnership desires to adopt a fiscal year ending September 30th. What is the result?

3. Same as question 2 above, except that B has a fiscal year ending in June

4. The Cannery, a calendar year partnership, desires to change from a calendar year to a fiscal year ending November 30th. The partnership has a canning season which extends from June 1st to November 1st. All partners are calendar year partners. Is the Commissioner likely to grant approval?

5. Same as question 3 above, except that the partnership has a canning season from September 1st to April 1st and desires to change to a fiscal year ending April 30th.