Dakotah Hills Offices Limited Partnership, An Arizona Limited Partnership, William M. and Dianne B. Stephens, Tax Matters Partners, et al. - Page 23

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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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