IRS Ruling 77-137 (Phantom Income) |
The IRS held that an assignee (judgement creditor) was the beneficial owner of such interest and as such "must report the distributive share of items of income, gain or loss, deduction, and credit attributable to the assigned interest... in the same manner and the same amounts that would be required if (the assignee) was a substituted partner (member)... even if such income is not distributed.