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SUBCHAPTER K [i] (MEMORANDUM 3, November 1, 1977)

handle is hein.ali/aliftp0349 and id is 1 raw text is: THIS DRAFT IS PRIVATE AND CONFIDENTIAL -
PUBLIC DISCLOSURE IS PROHIBITED*
(Not to be sold, offered for sale, or otherwise published)
THE AMERICAN LAW INSTITUTE

FEDERAL INCOME TAX PROJECT
SUBCHAPTER K

MEMORANDUM NO. 3

Subjects Coxrered:
A Full Fragmentation Approach as a Substitute
for the Present Collapsible Provisions, (§§731,
741 and 751); Payments to Retired Partners,
(§736); and Guaranteed Payments (§707(c)).

Submitted to the Consultants for consideration at their meeting
on November 18 (at 10:00 a.m.) and 19, 1977 at The Westbury
69th and Madison Avenue, New York, New York

November 1, 1977

The Executive Office
The American Law Institute
4025 Chestnut Street
Philadelphia, PA 19104

* This is a preliminary draft submitted on a private and
confidential basis to a limited group for the sole purpose
of study and criticism. It has not been promulgated or approved
by the Council or the mebers of The American Law Institute.
As an unpublished document intended for internal use, this
draft should not be generally circulated or distributed, nor
should it be quoted from or cited or its substance disclosed
in any public address or writing.

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