Tax Law Blog
Posts in Use Tax.
Posted by: Nicholas J. Stock II and Michael C. Zahrt
IRS has made a habit of challenging whether a member of a limited liability company that is treated as a partnership for tax purposes is materially participating in the activities of the partnership.
A recent Tax Court case (Strieby v. Commissioner) considers whether the passive activity credit limitation rules of Code Section 469 may prevent taxpayers from claiming energy credits allocated to them by virtue of their membership interests in a partnership.[1]
Facts Presented.
In Strieby, taxpayers invested in a solar farm but their only involvement consisted merely of completing ...
