Curtis R. and Lynn Bitker - Page 34

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          share of partnership liabilities); see also Tapper v. Commissioner,         
          T.C. Memo. 1986-597; cf. Coleman v. Commissioner, T.C. Memo.                
          1974-78 (Court refused to apply alternative computation because             
          taxpayer failed to provide proof of partnership’s asset basis),             
          affd. 540 F.2d 427 (9th Cir. 1976).  The computation may require            
          adjustments to reflect “any significant discrepancies arising as a          
          result of contributed property, transfers of partnership interest,          
          or distributions of property to partners.”  Sec. 1.705-1(b), Income         
          Tax Regs.                                                                   
               The record contains no evidence that any contributions were            
          entered on the Bitker partnership’s books at other than their tax           
          bases.  Nor does the record reflect any differences between the             
          financial and tax accounting treatment of partnership income or             
          expense items or partnership losses (before the year in issue) that         
          were not previously deductible by reason of section 704(d).  Nor is         
          an adjustment required for Ray Bitker’s transfer of his interest in         
          the Bitker partnership to petitioner husbands in 1989 or for                
          petitioner husbands’ transfers to petitioner wives in 1991 because          
          all of those transfers were gifts.  (The respective bases of                
          petitioners are determined using transferred bases for the                  
          interests received by gifts. Secs. 742, 1015(a); cf. Tapper v.              
          Commissioner, supra (adjustment required to reflect retirement of           
          former partner’s interest in prior year).)                                  








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