- 17 -
Cir. 1996). In addition, we may seek out any reliable evidence
as to the legislative purpose even where the statute is clear.
United States v. American Trucking Associations, Inc., supra at
543-544; Centel Communications Co. v. Commissioner, 92 T.C. 612,
628 (1989), affd. 920 F.2d 1335 (7th Cir. 1990). We use these
general principles of statutory interpretation to determine the
scope of section 1056 and/or the application of the subchapter K
basis adjustment rules.
The parties couch the question of whether section 1056
applies to the sale of an interest in a partnership holding a
sports franchise in terms of the threshold inquiry of whether a
partnership should be treated as an entity or aggregate. As
explained above, respondent seeks to employ the aggregate
approach to cause a more direct relationship to the partnership's
assets when an interest in the partnership changes hands.
Conversely, petitioner contends that the partnership should be
treated as an entity for purposes of our consideration of section
1056. In determining whether section 1056 should apply to the
sale of a partnership interest, our analysis considers both the
legislative intent in enacting section 1056 and the structure and
scope of the subchapter K basis adjustment rules.
1. Legislative Intent With Regard to the Application of Section
1056 to Partnership Transactions
"The theory concerning partnerships as entities is not
easily defined. It is well established that the partnership form
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