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(ii) Distributions from the partnership;
and
(iii) Transactions to which section 707(a)
applies (including the application of section
707(b)).
The regulations do not spell out all of the possible
items that can be related to such transactions. Rather,
as quoted above, the regulations state that any such
related items are partnership items, to the extent that a
determination of such items can be made from determinations
that the partnership is required to make for purposes of
the partnership books and records or for purposes of
furnishing information to a partner. Sec. 301.6231(a)(3)-
1(a)(4), Proced. & Admin. Regs. In the case of a
distribution from the partnership, the regulations state
that, for purposes of a partnership’s books and records or
for purposes of furnishing information to a partner, the
partnership needs to determine the character of the amount
transferred to a partner, the amount of money distributed
to a partner, the adjusted basis to the partnership of the
distributed property, and the character of the partnership
property. Sec. 301.6231(a)(3)-1(c)(3)(i), (ii), and (iii),
Proced. & Admin. Regs.
As explained above, an item is a partnership item to
the extent that a determination of the item can be made
from these and similar determinations that the partnership
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