- 28 - Code which assigns tax consequences to a disposition. See also Gulley v. Commissioner, T.C. Memo. 2000-190; Smith v. Commissioner, T.C. Memo. 1995-406. As the transfer of Mr. Katz’ partnership interests to his bankruptcy estate did not constitute a triggering event under section 706(c)(2), Mr. Katz did not thereby experience a “change in interest” under section 706(d)(1). Section 706(d)(1) thus has no application to this case. 4. Conclusion as to Disputed Allocation We hold that the prepetition partnership losses were properly reportable in their entirety by Mr. Katz’ bankruptcy estate pursuant to sections 706(a) and 1398(e).14 We therefore sustain respondent’s disallowance of the NOL carryovers claimed by petitioners for tax years 1991 to 1994, to the extent those carryovers are attributable to the prepetition partnership losses Mr. Katz claimed on his separately filed return for 1990. 14 To the extent not discussed in this opinion, we find petitioners’ arguments in favor of a contrary holding to lack merit.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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