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allocable shares of the other partners as reported by the
partnerships. Instead, it merely affects the Federal tax
liability of the specific partner whose status was changed from a
corporation to an individual. Items that merely affect the tax
liability of a specific partner, but not the other partners, are
not partnership items. Hambrose Leasing v. Commissioner, 99 T.C.
298, 308-309 (1992) (holding that a determination of the
partner’s amount at risk was not a partnership item because it
affected only the status of the partner and not the partnership);
N.C.F. Energy Partners v. Commissioner, 89 T.C. at 741 (holding
that penalties and additions to tax to be asserted against the
partners were not partnership items); Gustin v. Commissioner,
T.C. Memo. 2002-64 (holding that a partner’s basis in his
partnership interest is not a partnership item). Accordingly,
determining the identity of the partners is not a partnership
item under this regulation because it has no effect on either the
partnership’s aggregate or each partner’s share of income, gain,
loss, deductions, or credits of the partnership.
Second, respondent claims that section 301.6231(a)(3)-
1(a)(4), Proced. & Admin. Regs., includes as partnership items
any items relating to contributions to the partnership,
distributions from the partnership, and transactions between the
partnership and a partner not acting in his capacity as a
partner. Such items are only partnership items “to the extent
that a determination of such item can be made from determinations
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