Ezra Dyckman

December 28, 2005 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, wriote that partnerships are prized as investment vehicles for many reasons, not the least of which is the flexibility partnerships have in allocating income among partners, a flexibility which is, however, limited by a complex set of rules.

By Ezra Dyckman and Ronald A. Morris

8 minute read

June 25, 2008 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, an associate at the firm, write that despite the commonly held notion that partnerships afford nearly limitless flexibility as to how profit and loss will be allocated among partners, new Treasury regulations impose meaningful limits.

By Ezra Dyckman and Seth Hagen

8 minute read

February 25, 2009 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, an associate at the firm, write that although it is clear that two fee simple interests in real estate are of like kind for tax purposes regardless of the grade or quality of the real estate, harder questions and finer distinctions arise when analyzing more exotic interests arising from real estate.

By Ezra Dyckman and Seth Hagen

9 minute read

August 25, 2004 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, write that people often complain about how voluminous the Internal Revenue Code is. Sometimes, however, the most concise rules turn out to be the most difficult to apply.

By Ezra Dyckman and Ronald A. Morris

10 minute read

February 28, 2007 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth A. Hagen, an associate at the firm, review a recent IRS Chief Counsel Advice which treated the liquidating distribution of a house by a partnership to a partner as a taxable distribution of money. Although this holding is alarming at first glance, its scope and import are likely limited as the Advice responded to a particularly egregious set of facts.

By Ezra Dyckman and Seth A. Hagen

8 minute read

April 22, 2009 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Lana Kalickstein, an associate with the firm, write: Can a taxpayer acquire replacement property from a related party in a Section 1031 like-kind exchange? This simple question does not lend itself to an easy answer. Authority in this area is sparse; in fact, a decision of the Tax Court last month, Ocmulgee Fields Inc. v. Commissioner, is only the second case to shed light on this issue.

By Ezra Dyckman and Lana Kalickstein

9 minute read

October 22, 2008 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, and associate at the firm, write that perhaps in light of the recent financial troubles befalling the real estate development industry, the Treasury Department was especially receptive to this real estate industry's prayer for relief.

By Ezra Dyckman and Seth Hagen

8 minute read

October 27, 2004 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, write that although most people endeavor to avoid liabilities, partners frequently worry that they have too small a share of liabilities.

By Ezra Dyckman and Ronald A. Morris

7 minute read

April 23, 2002 | New York Law Journal

The Internal Revenue Service recently issued Revenue Procedure 2002-22, providing ruling guidelines for the tax classification of undivided fractional interests in rental real property. Although we continue to find clients to whom this comes as a surprise, section 1031 of the Internal Revenue Code prominently provides that the tax-free treatment accorded to like-kind exchanges does not apply to the exchange of partnership interests. Therefore, partnership interests cannot constitute either relinquished prop

By Ezra Dyckman And Ronald A. Morris

11 minute read

February 24, 2010 | New York Law Journal

Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, review a recent private letter ruling in which the IRS considered whether mezzanine financing, where debt is secured by interests in an entity that owns real property but not by the real property itself, can be qualified real property business indebtedness.

By Ezra Dyckman and Daniel W. Stahl

8 minute read