The Federal Definition of Tax Partnership

I. INTRODUCTION “When an entity must be classified for purposes of a Federal income tax statute, policy considerations of Federal income tax law should govern that classification . . . .”[1] Thus spoke the Tax Court, honoring federal income tax policy with its pen, but remaining far from it in application.[2] In fact, although the federal definition of tax[3] partnership has been at issue in over 150 statutes, cases, regulations,…