This article is an in-depth examination of section 709 of the Internal Revenue Code. Section 709, which was enacted in 1976, prescribed rules for the treatment of organization expenses and syndication expenses of a partnership.
II. Case Law Prior to Section 709 ... A. Historical Treatment of Organization and Syndication Expenses ... B. The Historical Foundation of Section 709
III. Legislative History of Section 709
IV. Section 709 Regulations
V. Section 709 Case Law ... A. Post-709, Pre-effective Date ... B. Post-709, Post-effective Date
VI. Planning Considerations
William M. Ojile Jr.,
Internal Revenue Code Section 709: To Deduct, Amortize, or Capitalize, That Is the Question,
65 Neb. L. Rev.
Available at: http://digitalcommons.unl.edu/nlr/vol65/iss2/6