- 23 - the following items which are required to be taken into account for the taxable year of a partnership under subtitle A of the Code are more appropriately determined at the partnership level than at the partner level and, therefore, are partnership items: (1) The partnership aggregate and each partner's share of the following: * * * * * * * (v) Partnership liabilities (including determinations with respect to the amount of the liabilities, whether the liabilities are nonrecourse, and changes from the preceding taxable year) * * * The regulations promulgated under section 6231(a)(3) also make clear that items related to certain transactions, including contributions to the partnership, distributions from the partnership, and transactions to which section 707(a) applies, are partnership items, at least in certain cases. Section 301.6231(a)(3)-1(a)(4), Proced. & Admin. Regs., provides as follows: (4) Items relating to the following trans- actions, to the extent that a determination of such items can be made from determinations that the partnership is required to make with respect to an amount, the character of an amount, or the percentage interest of a partner in the partner- ship, for purposes of the partnership books and records or for purposes of furnishing information to a partner: (i) Contributions to the partnership;Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011