13 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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