Many thanks to Keith Prescott, Dave Demille and Merrill Taylor of Wisan Smith Racker & Prescott, LLP for their thorough and practical presentation on the importance of understanding IRC 704(c) when drafting operating and partnership agreements. Here is a link to their written materials: Download file. You can email Keith (kprescott@wsrp.com ), Dave (ddemille@wsrp.com) or Merrill (mtaylor2@wsrp.com) for follow up questions and advice or visit their website, http://www.wsrp.com/ for more contact and other information about their practice.