When Hypothetical Liquidations Become “Illogical”: Otay Project LP v. Commissioner

The Tax Court’s recent decision in Otay Project LP v. Commissioner, T.C. Memo. 2026-21, is likely to become one of the most discussed partnership cases of the year — not because it announces a new doctrine, but because it quietly rewrites how § 743(b) is expected to operate in large tiered partnerships.... By: Offit Kurman