§624

ntil severance, a transfer ofthe fixture is a transfer ofreal property. Id. To effect a constructive severance ofabuilding from land, the transfer ordinarily must be in a writing in a form sufficient for a conveyance ofland, 2 Tiffany Real Property, sec. 624 (3d ed. 1939); i.e., to effect a constructive severance, the writing must convey ownership and title to the building. The grant ofan easement, a lease, or a license will not constructively sever the building from the land. - 29 - Granting a

severance, a transfer of the fixture is a transfer of real property. Id. To effect a constructive severance of a building from land, the transfer ordinarily must be in a writing in a form sufficient for a conveyance of land, 2 Tiffany Real Property, sec. 624 (3d ed. 1939); i.e., to effect a constructive severance, the writing must convey ownership and title to the building. The grant of an easement, a lease, or a license will not constructively sever the building from the land. Granting a fire d

ffect a constructive severance of the building from the underlying land. To effect a constructive severance of a building from land, the transfer ordinarily must be in a writing in a form sufficient for a conveyance of land. 2 Tiffany Real Property, sec. 624 (3d ed. 1939). Respondent contends that the letters between petitioner and the VFD were insufficient under the Wisconsin statute of frauds, Wis. Stat. Ann. sec. 706.02 (West 2001), to convey such an,interest. We disagree. Under Wis. Statt. A

ffect a constructive severance of the building from the underlying land. To effect a constructive severance of a building from land, the transfer ordinarily must be in a writing in a form sufficient for a conveyance of land. 2 Tiffany Real Property, sec. 624 (3d ed. 1939). Respondent contends that the letters between petitioner and the VFD were insufficient under the Wisconsin statute of frauds, Wis. Stat. Ann. sec. 706.02 (West 2001), to convey such an interest. We disagree. Under Wis. Stat. An

pter S item" within the meaning of former section 6245 .12 We acknowledged that the partnership audit and litigation provisions contained i sections 6221-6231 "were, in effect, grafted onto the subchap er S audit and litigation provisions" by former section 624 , .id. at 3, and we held that a member's basis in the passthrough entity was not an item "required" to be taken into account by he entity for the entity's taxable year, id. at 5-6 . We con lude that it is not necessary or appropriate to d

624(a), 98 Stat. 922. In the Tax Reform Act of 1986, Congress decided to extend the rebate requirements to additional classes of tax-exempt bonds, including those issued to provide multifamily residential housing.5 See Tax Reform Act of 1986 (TRA), Pub. L. 99-514, sec. 1314(d), 100 Stat. 2664. With this change came new rules relating to the 5