Partnership formation, including but not limited to:

• Characterizing various items as property;
• Receipt of partnership interest in exchange for services;
• Contract review for acquisition of partnership interests;
• Drafting and creating thousands of entities that are taxed as partnerships for federal income tax purposes;
• Advising on Section 83(b) and protective 83(b) elections;
• Contribution of appreciated property and analyzing the three different 704(c) allocation methods (traditional, traditional with curative, remedial) as well as analyzing such methods for depreciable property;
• Contributions of depreciable property;
• Character of gains and losses from disposition of contributed property;
• Contributions of encumbered property;
• Contributions of accounts receivable and payable; and
• Organization and syndication expenses.