- 10 - IDC in calculating petitioner's basis in each partnership. Thus, petitioner argues that respondent's reliance on the Schedules K-1 results in a double counting of IDC, improperly reducing petitioner's basis. This view is incorrect. In general, deductible items reduce both the partnership's taxable income and each partner's basis in the partnership. Pursuant to section 703, a partnership computes its taxable income in the same manner as an individual, except that certain items must be stated separately and certain deductions are not allowed. IDC is an item that must be stated separately. Sec. 1.702-1(a)(8)(i), Income Tax Regs. Thus, in determining his income tax, petitioner must take into account his distributive share of loss due to IDC. Sec. 702(a). Pursuant to section 705(a), a partner's adjusted basis in his partnership interest is increased by the partner's distributive share of taxable income of the partnership and decreased by the partner's distributive share of losses of the partnership. Thus, petitioner's adjusted basis in each partnership interest was properly increased by petitioner's distributive share of taxable income of the partnership, net of petitioner's distributive share of IDC. The deduction for IDC affects both petitioner's ultimate distributive share of partnership income and petitioner's basis in the partnership interest. Thus, reliance on the Schedules K-1 does not result in an improper double counting. On brief respondent relied on the Schedules K-1 in computing petitioner's basis by taking the capital account balance at thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011