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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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