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list of items which the Treasury Department has concluded are
partnership items. That list includes the “partnership aggregate
and each partner’s share of * * * (i) Items of income, gain,
loss, deduction, or credit of the partnership; * * * [and]
(v) Partnership liabilities (including determinations with
respect to the amount of the liabilities * * * and changes from
the preceding taxable year)”. Sec. 301.6231(a)(3)-1(a)(1),
Proced. & Admin. Regs. That list also includes items relating to
distributions from the partnership to the extent that a
determination of those items can be made from conclusions that
the partnership is required to make with respect to an amount,
the character of an amount, or the percentage interest of a
partner in the partnership, for purposes of the partnership books
and records or for purposes of furnishing information to a
partner. Sec. 301.6231(a)(3)-1(a)(4), Proced. & Admin. Regs.
The regulations state further that a partnership item not only
includes those items expressly listed in the regulations, but
also includes “the legal and factual determinations [e.g., the
partnership’s taxable year] that underlie the determination of
the amount, timing, and characterization of items of income,
credit, gain, loss, deduction, etc.” Sec. 301.6231(a)(3)-1(b),
Proced. & Admin. Regs.
Collins disputes in the Form 8082 the four items discussed
supra pp. 14-15. Each of these items is an HCMP partnership item
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