Episode 9 - Ogden v. Commissioner

One of my favorite topics - Operating Agreement tax allocation language!

Maybe one of the biggest things to get right when talking about partnership tax returns is the allocation of income and loss. It's not as straight forward as many think it is.

In Ogden v. Commissioner (from 1985), the taxpayer had the majority of her loss taken away after the Court saw the operating agreement didn't have the right language.

Enjoy!