Ezra Dyckman

February 22, 2006 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of the law firm Roberts & Holland, write that as like-kind exchanges continue to grow in number and size, many of the details involved are being focused upon with renewed energy. Some of the "nuts and bolts" are vital to the qualification of an exchange. Others go to minimizing taxable "boot" or relate to proper post-exchange tax reporting. New proposed regulations, actually "reproposed regulations," were just issued addressing one of these details.

By Ezra Dyckman and Ronald A. Morris

8 minute read

December 27, 2006 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, writes the Internal Revenue Service has just released a Chief Counsel Advice (written advice by the Internal Revenue Service's office of chief counsel directed to other IRS employees) on the subject of interest capitalization, which may shed light on the issue of whether an item that is treated as personal property for depreciation purposes must also be treated as personal property for like kind exchange purposes.

By Ezra Dyckman and Ronald A. Morris

6 minute read

August 22, 2007 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, and Nathan K. Tasso, also with the firm, review a recent decision from the Court of Federal Claims and the proposed Treasury Regulations dealing with the deductibility of environmental cleanup costs.

By Ezra Dyckman, Ronald A. Morris and Nathan K. Tasso

6 minute read

June 24, 2009 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Libin Zhang, an associate with the firm, write that the Treasury has recently issued Proposed Treasury Regulation �1.706-4, which provides detailed rules for how partnerships items should be allocated to partners who vary their partnership interests during the partnership's taxable year. The rules, they say, apply to any variations in partnership interests that occur not only when partners make complete dispositions of their partnership interests, as under the current regulations, but also when partners make partial dispositions of their partnership interests.

By Ezra Dyckman And Libin Zhang

9 minute read

February 26, 2002 | New York Law Journal

I nternal Revenue Code section 1031 provides that gain or loss is not generally recognized with respect to the disposition of property to the extent that such property is exchanged for like-kind property.

By Ezra Dyckman And Ronald A. Morris

10 minute read

April 27, 2011 | New York Law Journal

In their Taxation column, Ezra Dyckman and Daniel W. Stahl of Roberts & Holland discuss the recent Historic Boardwalk Hall, LLC v. Commissioner decision, to weigh the potential pitfalls of Congress' encouragement of the rehabilitation of historic structures by providing that taxpayers could receive federal tax credits by engaging in restoration projects.

By Ezra Dyckman and Daniel W. Stahl

8 minute read

March 27, 2006 | The Recorder

New proposed rules will have an effect on the tax treatment of real estate exchanges.

By Ezra Dyckman and Ronald A. Morris

8 minute read

August 26, 2009 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, an associate of the firm, write: Generally, where an investor holds an interest in an activity through a limited partnership interest, the investor's involvement is presumed to be passive and losses from that activity may only be used to offset income from other passive sources. Recently however, the U.S. Tax Court and the U.S. Court of Federal Claims each held that the general partner exception applies to block that presumption. But before tax practitioners and real estate investors uncork the champagne, closer scrutiny of the cases' impact is warranted.

By Ezra Dyckman and Seth Hagen

11 minute read

June 27, 2007 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, write that in a favorable (but confusing) twist, new IRS regulations provide that for purposes of determining which depreciation period is longer, the replacement property is deemed to have the depreciation period it would have had had it been placed in service at the time the relinquished property was placed in service.

By Ezra Dyckman and Ronald A. Morris

9 minute read

August 27, 2008 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, an associate at the firm, write that despite the benefits offered by using a Series LLC, thus far, their use in the real estate industry has been scarce. A major factor contributing to the disuse of the Series LLC has been the uncertainty for federal tax purposes as to how the entity will be treated--as one entity or several. Although the question has not yet been firmly settled, the IRS recently published a private letter ruling providing guidance on this issue.

By Ezra Dyckman and Seth Hagen

8 minute read