57 Reg. 1.752-2(k)(3). 58
See, e.g., McKee, Nelson & Whitmire, Federal Taxation of Partnerships and Partners (WG&L, 2009), 7 8.02[8].
59
Fenwick, McLoughlin, Salmon, Smith, Tilley, and Wood, State Taxation of Pass-Through Entities and Their Owners (WG&L, 2009), Appendix, Tables 8 and 9. Alabama, California, New Jersey, New York, Pennsylvania, Tennessee, and Texas are a few of the states that impose various entity-level taxes or fees on LLCs.
60
Fenwick, McLoughlin, Salmon, Smith, Tilley, and Wood, State Taxation of Pass-Through Entities and Their Owners (WG&L, 2009), 918.03.
54 AFTR 2d 84-5072, 735 F2d 704, 84-1 USTC 99505 (CA-2, 1984). 63 Pennsylvania Personal Income Tax Guide (03/06).
64
See e.g., Cleveland Browns Transportation LLC, TSB-A-06(8)S, 03/06/06 (sales of transportation services to an operating entity by its wholly owned and income tax disregarded LLC were recognized for sales tax purposes).
65
REG-113462-08, 12/22/08. ——$—— ns
Reg. 1.881-3(a)(2)(i)(A). 67
Reg. 1.881-3(a)(2)(ii)(A). 68
Reg. 1.881-3(a)(1). 69
Supra note 65,
70
Prop. Reg. 1.881-3(a)(2)(i)(C). The proposed regulation does not expressly apply to any DREs not within the ambit of the check-the-box regulations.
Supra note 65,
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