- 32 - The parties refer to Rev. Rul. 66-58, 1966-1 C.B. at 187, in which the tax treatment of the sale of cotton acreage allotments was addressed. In the ruling, it is stated that-- Where a taxpayer has acquired * * * [a cotton] allotment along with the land to which it relates, as a unit, the cost or other basis of the entire unit should be allocated between the land and the allotment in accordance with the relative fair market values of such properties on the date of acquisition. * * * The ruling, however, also explains-- Of course, no portion of the basis of land, acquired prior to the issuance of the cotton allotment, can be allocated to such allotment. Our discussion of the partnership's water rights in the context of the above capital asset issue (namely, among other things, that water rights the partnership received in 1983 related to and were dependent upon the land the partnership acquired in 1976) is not inconsistent with our analysis and holding on the instant issue that the water rights were sufficiently distinct and separate from the partnership's ownership interest in the land to preclude any allocation of the partnership's cost or tax basis in the land to the partnership's water rights. The partnership's water rights were related to and dependent upon the partnership's land ownership, and the partnership's water rights constituted capital assets of the partnership. At the same time, however, as discussed, the partnership's waterPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011