Ridge L. Harlan and Marjory C. Harlan - Page 22




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               A. General rules (secs. 701-707)                                       
                    (1) Income of partners.--Under your committee’s bill,             
               as under present law, partners will be liable individually             
               for income tax on their distributive shares of partnership             
               income.  The bill provides that the partnership will act as            
               a mere conduit as to income and loss items, transferring               
               such items directly to the individual partners.                        
                    The items required to be segregated will retain their             
               original character in the hands of the partner as though               
               they were realized directly by him from the same source from           
               which realized by the partnership and in the same manner.              
               After excluding the items required to be separately treated,           
               the remaining income or loss, which corresponds to the                 
               ordinary income or loss of the partnership under present               
               law, is attributed to the partners.                                    
                    The computation of partnership income is generally on             
               the same basis as existing law.  The partnership is allowed            
               the usual business deductions, but is denied the deductions            
               peculiar to individuals.                                               
                    The bill provides that all elections with respect to              
               income derived from a partnership (other than the election             
               to claim a credit for foreign taxes) are to be made at the             
               partnership level and not by the individual partners.  This            
               rule recognizes the partnership as an entity for purposes of           
               income reporting.  It avoids the confusion which would occur           
               if each partner were to determine partnership income                   
               separately for his own purposes.                                       
                    (2) Distributive shares.--The taxation of partnership             
               income or other items directly to the partners requires a              
               determination of each partner’s share of such items.  In               
               general, such shares will be determined in accordance with             
               the partnership agreement as under existing practice.                  
          The report goes on to state as follows, id. at A221, A222:                  
               Section 702. Income and credits of partner                             
                    This provision represents no change in current law and            
               practice.  It incorporates provisions of sections 182,                 
               183(c), 184, 186, and 189 of present law.                              
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