- 25 - 705(a) provides that the adjusted basis of a partner’s interest in a partnership is the basis as determined under section 7225 (relating to contributions to a partnership) or section 7426 (relating to transfers of partnership interests) (1) increased by the partner’s distributive share of partnership income for the current and prior years and (2) decreased (but not below zero) by the amount of distributions from the partnership under section 7337 and by the partner’s distributive share of partnership losses for the current and prior years. 5 Sec. 722 provides that the basis of a partnership interest acquired by contribution of property, including money, is “the amount of such money and the adjusted basis of such property to the contributing partner at the time of the contribution”. For purposes of sec. 722, a contribution of money includes: “Any increase in a partner’s share of the liabilities of a partnership, or any increase in a partner’s individual liabilities by reason of the assumption by such partner of partnership liabilities”. Sec. 752(a). 6 Sec. 742 provides: “The basis of an interest in a partnership acquired other than by contribution shall be determined under part II of subchapter O (sec. 1011 and following).” In general, the basis of property acquired by gift is the same as it was in the hands of the donor. Sec. 1015. For purposes of determining loss, however, if that basis is greater than the fair market value of the property at the time of the gift, then the basis is the fair market value at the time of the gift. Id. 7 In the case of a distribution by a partnership to a partner other than in liquidation of a partner’s interest, the adjusted basis of the partner is reduced by the amount of money distributed to that partner. Sec. 733. Additionally, any decrease in a partner’s share of the liabilities of a partnership is considered a distribution of money to the partner by the partnership. Sec. 752(b).Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011