Dakotah Hills Offices Limited Partnership, An Arizona Limited Partnership, William M. and Dianne B. Stephens, Tax Matters Partner, et al. - Page 11

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          determining his or her income tax, a partner must take into                 
          account his "distributive share" of each item of partnership                
          income, gain, loss, deduction, and credit.  Sec. 702.  Each                 
          partner is taxed on his distributive share of partnership income            
          without regard to whether the income is actually distributed to             
          him.  Sec. 1.702-1(a), Income Tax Regs.  Section 722 provides               
          that the basis of a partnership interest acquired by contribution           
          of money or other property to a partnership is the amount of such           
          money, and the adjusted basis of such property, increased by any            
          gain recognized under section 721(b) to the contributing partner            
          at such time.                                                               
               A partner's basis of his partnership interest is subject to            
          adjustments.  In particular, a partner's share of liabilities of            
          the partnership are included in computing the partner's tax basis           
          of his partnership interest.  Cf. Crane v. Commissioner, 331 U.S.           
          1 (1947).                                                                   
               Section 752(a) provides that any increase in a partner's               
          share of the liabilities of a partnership, or any increase in a             
          partner's individual liability by reason of the assumption by               
          such partner of partnership liabilities, shall be considered a              
          contribution of money by such partner to the partnership.  This             
          contribution results in an increase in the partner's basis of his           
          partnership interest.  Sec. 722.                                            
               Section 752(b) provides that any decrease in a partner's               
          share of the liabilities of a partnership, or any decrease in a             




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