Question
Refer to the attached article entitled: Campbell v. Commissioner: Is There Now Little or No Chance of Taxation of a Profits Interest in a Partnership?
Refer to the attached article entitled: Campbell v. Commissioner: Is There Now "Little or No Chance" of Taxation of a "Profits" Interest in a Partnership? Thinking critically about The Eighth Circuit decision that found that the Tax Court's valuation was clearly erroneous See attached articles for reference. The Eighth Circuit set forth its reasoning: "The tax court relied too heavily on the fact that the Class A limited partners were willing to pay substantial sums for their interests at the same time Campbell received his interest. Because of the difference in the nature of the investments, we believe that this fact is not relevant. The Class A limited partners had superior rights to cash distributions and return of capital, as well as some rights of participation. Further, the court should not have disregarded the expert's belief that the tax benefits were speculative in nature. Do you agree with The Eighth Circuits decision? Why, or why not?
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