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partnership was required to make a determination of that
item. Id.
As mentioned above, the regulations require a part-
nership to determine the partnership aggregate and each
partner’s share of “Partnership liabilities (including
determinations with respect to * * * changes from the
preceding taxable year)”. Sec. 301.6231(a)(3)-1(a)(1)(v),
Proced. & Admin. Regs. The determination of the items at
issue in this case, the amount of money treated as a
distribution to the partner by the partnership under
section 752(b), flows automatically from the determination
that partnership liabilities have decreased from the
preceding taxable year. Accordingly, in view of section
301.6231(a)(3)-1(a)(1)(v), Proced. & Admin. Regs., which
requires the partnership to determine the partnership
aggregate and each partner’s share of partnership
liabilities, including changes from the prior year, we
conclude that the determination of a constructive
distribution of money under section 752(b) that is brought
about by a decrease in a partner’s share of the liabilities
of a partnership is also a partnership item.
Petitioners do not discuss section 301.6231(a)(3)-1(a)
(1)(v), Proced. & Admin. Regs. Rather, as mentioned above,
petitioners focus their argument on the rules set forth in
section 301.6231(a)(3)-1(a)(4), Proced. & Admin. Regs.,
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