Revised sec. 6621(c)(2) hot interest provision.(IRC section 6621(c)(2) regarding corporate tax underpayments)Martin, LindaRaynard, SandyBessinger, Randy
IRC Section 1061(a) applies to taxpayers that hold "applicable partnership interests" (APIs). An API is defined as a partnership interest that is transferred to, or held by, a taxpayer in connection with the performance of substantial ser...