Thomas Louis Mitchell - Page 10

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          IDC in calculating petitioner's basis in each partnership.  Thus,           
          petitioner argues that respondent's reliance on the Schedules K-1           
          results in a double counting of IDC, improperly reducing                    
          petitioner's basis.  This view is incorrect.                                
               In general, deductible items reduce both the partnership's             
          taxable income and each partner's basis in the partnership.                 
          Pursuant to section 703, a partnership computes its taxable                 
          income in the same manner as an individual, except that certain             
          items must be stated separately and certain deductions are not              
          allowed.  IDC is an item that must be stated separately.  Sec.              
          1.702-1(a)(8)(i), Income Tax Regs.  Thus, in determining his                
          income tax, petitioner must take into account his distributive              
          share of loss due to IDC.  Sec. 702(a).  Pursuant to section                
          705(a), a partner's adjusted basis in his partnership interest is           
          increased by the partner's distributive share of taxable income             
          of the partnership and decreased by the partner's distributive              
          share of losses of the partnership.  Thus, petitioner's adjusted            
          basis in each partnership interest was properly increased by                
          petitioner's distributive share of taxable income of the                    
          partnership, net of petitioner's distributive share of IDC.  The            
          deduction for IDC affects both petitioner's ultimate distributive           
          share of partnership income and petitioner's basis in the                   
          partnership interest.  Thus, reliance on the Schedules K-1 does             
          not result in an improper double counting.                                  
               On brief respondent relied on the Schedules K-1 in computing           
          petitioner's basis by taking the capital account balance at the             



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