- 11 - Petitioners stipulated that the partnership interest was community property. Under Texas law, therefore, income and deductions attributable to the partnership interest are petitioners' community property. We conclude that Susan had a community interest in the COD income of the partnership that flowed through to James (i.e., she owned one-half of the COD income). Thus, under section 108(b), petitioners must reduce Susan's NOL by her COD income. To reflect the foregoing, Decision will be entered under Rule 155. 9(...continued) court we may look to the State's lower courts' rulings and holdings. Commissioner v. Estate of Bosch, 387 U.S. 456, 465 (1967).Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011