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LAURA E. CUNNINGHAM and NOEL B. CUNNINGHAM, The Logic of Subchapter K: A Conceptual Guide to Taxation of Partnership (St. Paul, MN: West, 2006, 247, $74.00).
It is safe to state that every M.S. in Taxation and every LL.M. in Taxation program has a course offering in partnership taxation. Most, if not all, require tax students to take such a course as one of the core classes (nonelectives) toward a degree. At times, partnership taxation may be covered in a course that focuses on taxation of flow-through entities, a course that typically covers taxation partnerships and S corporations. With the advent and proliferation of limited liability companies electing to be taxed as partnerships, as well as the prevalence of many hedge funds set up as partnerships, it has become increasingly important for tax students, as well as tax professionals, to gain a decent knowledge of and familiarity with partnership taxation.
During the 2010 summer semester, for the first time, I adopted The Logic of Subchapter K: A Conceptual Guide to Taxation of Partnership (Logic) as a textbook for my three-credit partnership taxation course at the Fairleigh Dickinson University's M.S. in Taxation program. The course spanned 15 weeks, meeting once a week in the evenings for roughly 2.5 hours. Logic is an in-depth comprehensive work on partnership taxation. It is a terrific resource and an indispensible research tool, particularly so once one has already gained some familiarity with and a working knowledge of a given area and then needs or wishes to burrow deeper into intricacies and theoretical issues. Copious footnote citations serve as guideposts for follow-up research and readings. For most tax programs, adopting such a text as the main and only text might be biting off too much for neophyte students. It can be a challenge to use such a text without getting bogged down or sidetracked with some minor points. Partnership taxation is a very challenging area of tax law; some claim that it is one of the more, if not most, difficult subject areas. As there are many complex topics and much to cover within a semester, it is important to stay the course with clear, concise, and brief coverage. Logic does that in a commendable way.
Logic works well whether...