- 34 - 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).)Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
Last modified: May 25, 2011