What is the name of your state? Indiana
What if someone holds both a capital interest and a profits only interest in a partnership...are they treated as one "hybrid" interest for purposes of Sec. 83 for which a Sec. 83(b) election would be required or would they be treated as separate interests and thus no 83(b) election would be required pursuant to Rev. Procs. 2001-43 and 93-27? Thanks.
What if someone holds both a capital interest and a profits only interest in a partnership...are they treated as one "hybrid" interest for purposes of Sec. 83 for which a Sec. 83(b) election would be required or would they be treated as separate interests and thus no 83(b) election would be required pursuant to Rev. Procs. 2001-43 and 93-27? Thanks.