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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;
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