Salina Partnership LP - Page 36




                                       - 36 -                                         
          approach, which recognizes a partnership as an entity separate and          
          distinct from its partners, is reflected in part in section 703(a),         
          which provides that items of income, gain, loss, deduction, and             
          credit are determined at the entity or partnership level.  The              
          aggregate approach, which recognizes a partnership as an aggregate          
          of its partners, is reflected through provisions such as sections           
          701 and 702, which provide that partnership items are passed                
          through the partnership to its individual partners for purposes of          
          imposing income tax.  See United States v. Basye, 410 U.S. 441, 448         
          (1973).                                                                     
               In an effort to avoid distortions in income tax reporting              
          associated with the blending of the entity and aggregate approaches         
          within subchapter K, Congress enacted a number of provisions that           
          generally are intended to equate the aggregate of the partnership’s         
          inside bases in its assets with the aggregate of its partners’              
          outside bases in their partnership interests.  See 1 McKee et al.,          
          Federal Taxation of Partnerships and Partners, par. 6.01, at 6-3            
          (3d ed. 1997) (McKee).  The carryover-basis rules contained in              
          section 722, which provide that a partner’s basis in his                    
          partnership interest equals the amount of money plus the adjusted           
          basis of property contributed to a partnership, generally results           
          in a matching of inside and outside bases upon the formation of a           
          partnership.  See Coloman v. Commissioner, 540 F.2d 427, 429 (5th           
          Cir. 1976), affg. T.C. Memo. 1974-78.  Similarly, adjustments to            
          basis prescribed under section 705(a) to account for income and             




Page:  Previous  26  27  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  43  44  45  Next

Last modified: May 25, 2011