Victor Grigoraci and Judith A. Grigoraci, et al. - Page 13




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          determinations in these cases.  The determinations in Hang and              
          Katz had no impact on the entity’s aggregate income, gain, loss,            
          deductions, or credits.  In the cases at hand, respondent’s                 
          alteration of the partners in GTWP and TWA had no impact on                 
          either partnership’s aggregate income, gain, loss, deductions, or           
          credits.  The determination in Katz also had no impact on the               
          other partners’ shares of the income, gain, loss, deductions, or            
          credits of the partnership.  Similarly, in these cases,                     
          reallocation of the distributive share of any corporate partner             
          of record to the individual who owns such Corporation has no                
          impact on the other partners’ shares of the income, gain, loss,             
          deductions, or credits.                                                     
               Respondent claims that section 301.6231(a)(3)-1, Proced. &             
          Admin. Regs., mandates that items that are required to be taken             
          into account under Subtitle A by the partnership are, by                    
          definition, more appropriately determined at the partnership                
          level and are, therefore, partnership items.  We disagree.  The             
          regulation provides a list of items that are more appropriately             
          determined at the partnership level from the larger universe of             
          items that are required to be taken into account under Subtitle             
          A.  See Harris v. Commissioner, 99 T.C. 121, 125 (1992).  It does           
          not state that all items that must be taken into account under              
          Subtitle A are ipso facto more appropriately determined at the              
          partnership level.                                                          






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