Interhotel Company, Ltd. - Page 33




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               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 language           






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