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    SmartBrief enables case brief popups that define Key Terms, Doctrines, Acts, Statutes, Amendments and Treatises used in this case.

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    Business Planning Keyed to Gevurtz

    PNRC Limited Partnership v. Commissioner of Internal Revenue

    Citation:

    66 T.C.M. (CCH) 265 (1993)

    Facts

    Clark Raymond & Co., PLLC (CRC) was an accounting firm with three partners in 2013: Clark PLLC, Newman PLLC, and Town PS. The partnership operated under a 2013 LLC Agreement that included provisions for capital account maintenance, income allocations, distributions, and a qualified income offset (QIO). In May 2013, Newman PLLC and Town PS withdrew from CRC and formed their own firm, NT PLLC. Certain clients ceased engaging CRC and began using NT PLLC’s services. CRC reported these clients as property distributions to the withdrawing partners valued at $742,569 ($318,144 to Newman PLLC and $424,425 to Town PS). CRC decreased the withdrawing partners’ capital accounts by these amounts, creating negative balances. To restore these negative balances to zero, CRC allocated all of its $563,118 ordinary income for 2013 to Newman PLLC and Town PS pursuant to the QIO provision, leaving no taxable income allocated to Clark PLLC. The IRS challenged these allocations in an FPAA, determining that the client distributions should be disregarded and that the income allocations lacked substantial economic effect.

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    PNRC Limited Partnership v. Commissioner of Internal Revenue