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in January 1986. In effect, respondent appears to treat
the joint venture like a corporation, the activities of
which are not ordinarily attributable to its shareholders.
E.g., Bramblett v. Commissioner, supra at 533. It is clear
that the trade or business of a corporation is distinct
from the trades or businesses of its stockholders. E.g.,
Whipple v. Commissioner, 373 U.S. at 202. On the other
hand, the trade or business of a joint venture or partner-
ship is the trade or business of each of the venturers or
partners. See generally Flood v. United States, 133 F.2d
173 (1st Cir. 1943); Butler v. Commissioner, 36 T.C. 1097
(1961); Bauschard v. Commissioner, 31 T.C. 910 (1959);
Ward v. Commissioner, 20 T.C. 332 (1953), affd. 224 F.2d
547 (9th Cir. 1955). In Stanchfield v. Commissioner, T.C.
Memo. 1965-305, we stated as follows:
While we agree with the Whipple opinion that
the trade or business of a corporation is
distinct from the trades or businesses of
its stockholders, we do not believe that a
similar distinction can be made in the case
of a partnership and its partners.
For example, in Butler v. Commissioner, supra, the issue
was whether or not certain loans made by a taxpayer to a
partnership of which he was a limited partner were to be
treated as business or nonbusiness bad debts. We noted
that by reason of his position as a limited partner the
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