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          bankruptcy estate held beneficial ownership of the partnership              
          interests as of the close of the various partnership taxable                
          years, it is incumbent upon petitioners to identify an exception            
          to the section 706(a) general rule in order for the prepetition             
          partnership losses to be allocated to Mr. Katz in his individual            
          capacity.  In this regard, petitioners offer section 706(d)(1).             
               Petitioners argue that the varying interests rule under                
          section 706(d)(1) was triggered when Mr. Katz filed his chapter 7           
          petition in bankruptcy.  Section 706(d)(1), enacted as part of              
          the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, sec.             
          72, 98 Stat. 494, 589, provides in pertinent part as follows:               
                    (1) In general.–- * * * if during any taxable year                
               of the partnership there is a change in any partner’s                  
               interest in the partnership, each partner’s                            
               distributive share of any item of income, gain, loss,                  
               deduction, or credit of the partnership for such                       
               taxable year shall be determined by the use of any                     
               method prescribed by the Secretary by regulations which                
               takes into account the varying interests of the                        
               partners in the partnership during such taxable year.                  
               [Emphasis added.]                                                      
          In particular, petitioners contend that Mr. Katz experienced a              
          “change in interest” under section 706(d)(1) when his ownership             
          interests in the partnerships were extinguished by the operation            
          of 11 U.S.C. sec. 541(a)(1).  The argument follows that each                
          partnership was required under section 706(d)(1) to make an                 
          allocation in respect of Mr. Katz’ extinguished interest.                   
               Respondent contends that section 706(d)(1) has no                      
          application to a transfer of a partnership interest pursuant to             
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