- 10 -10 Commissioner, T.C. Memo. 1988-195; Lynch v. Commissioner, T.C. Memo. 1982-305; Abraham v. Commissioner, T.C. Memo. 1970-304. A partner's adjusted basis in his partnership interest is determined under section 705. A partner's initial basis in a partnership is determined by the amount of money contributed and the adjusted basis of any other type of property contributed. Sec. 722. The partner's basis in the partnership is then adjusted upward for the partner's distributive share of separately stated income items, and downward by distributions of money (including the relinquishment of liabilities) or the adjusted basis of other property distributed, and the partner's distributive share of losses and nondeductible expenses. Sec. 705; La Rue v. Commissioner, 90 T.C. 465, 477 (1988). Petitioner claims a $121,500 basis2 in the partnership due to the "value" of his interest in accounts receivable and work in progress for work he performed for clients of the law firm. Petitioner explains on brief: A partner's basis for his interest in a partnership depends on how he acquired it. It may consist of the amount of cash he 2 At trial, petitioner calculated his basis in his partnership interest by adding the amount of accounts receivable and costs associated with petitioner's clients ($93,744.68) with current work in progress ($65,485.20), for a total of $159,229.88. Petitioner then applied a collection rate which reduced the total figure to $121,500.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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