Dakotah Hills Offices Limited Partnership, An Arizona Limited Partnership, William M. and Dianne B. Stephens, Tax Matters Partners, et al. - Page 24

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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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