- 33 - partnership increases the partner’s capital account, the allocation cannot have economic effect because the minimum gain merely offsets nonrecourse deductions previously claimed by the partnership and does not necessarily bear any relationship to the value of partnership property. Thus, minimum gain that is attributable to nonrecourse deductions claimed by the partnership must be allocated to the partners that were allocated such nonrecourse deductions to prevent such gain from impairing the economic effect of other partnership allocations. * * * [Id.] The regulations thus implement the Tufts doctrine that deductions based on nonrecourse financing will later be offset by increased income, even though that income is not realized in an economic sense. Here, IHCL had passed through nonrecourse deductions to its partners. The regulations require that a subsequent deemed liquidation of IHCL generates gains, albeit noncash, to offset previously claimed deductions. Those gains increase the upper tier partners’ capital accounts pro tanto. Respondent’s insistence that a deemed liquidation must produce actual economic gains to offset nonrecourse deductions is inconsistent with the logic of Tufts. Other provisions of the regulations do not mandate a different result. Respondent refers to language of section 1.704- 1T(b)(4)(iv)(e)(2), Temporary Income Tax Regs., 53 Fed. Reg. 53163 (Dec. 30, 1988), to the effect that if there is a net decrease in partnership minimum gain, then each partner “must be allocated items of income and gain for such year (and, if necessary, for subsequent years)”. Respondent argues the parenthetical languagePage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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