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.

I. Introduction

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

VII. Conclusion