Joseph D. Doll and Charlotte J. Doll - Page 6

                                        - 6 -                                         
          burden to respondent.  Petitioner has not substantiated the items           
          at issue, including the basis of his partnership interest, and              
          therefore, the burden remains on petitioner.                                
          II.  Sale of Partnership Interest                                           
               Section 741 provides that the sale or exchange of a                    
          partnership interest shall, except to the extent section 751                
          applies, be treated as the sale or exchange of a capital asset.             
          Gain or loss from the sale of a partnership interest is measured            
          by the difference between the amount realized and the adjusted              
          basis of the partnership interest.  Sec. 1001(a).                           
               The amount realized is the sum of any money received plus              
          the fair market value of property received.  Sec. 1001(b).  A               
          partner’s adjusted basis in his partnership interest is generally           
          the basis of such interest determined under section 722,                    
          increased or decreased by the partner’s distributive share of               
          income, loss, and certain other items.  Sec. 705.  The basis of             
          an interest in a partnership acquired by a contribution of                  
          property, including money, is the amount of money and adjusted              
          basis of such property to the partner at the time of                        
          contribution, increased by the amount of any gain recognized                
          under section 721(b) at the time.  Sec. 722.  Any increase in a             
          partner’s share of liabilities of the partnership is considered a           
          contribution by such partner to the partnership and increases the           
          basis of the partner’s interest in the partnership.  Sec. 752(a).           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011