- 6 - burden to respondent. Petitioner has not substantiated the items at issue, including the basis of his partnership interest, and therefore, the burden remains on petitioner. II. Sale of Partnership Interest Section 741 provides that the sale or exchange of a partnership interest shall, except to the extent section 751 applies, be treated as the sale or exchange of a capital asset. Gain or loss from the sale of a partnership interest is measured by the difference between the amount realized and the adjusted basis of the partnership interest. Sec. 1001(a). The amount realized is the sum of any money received plus the fair market value of property received. Sec. 1001(b). A partner’s adjusted basis in his partnership interest is generally the basis of such interest determined under section 722, increased or decreased by the partner’s distributive share of income, loss, and certain other items. Sec. 705. The basis of an interest in a partnership acquired by a contribution of property, including money, is the amount of money and adjusted basis of such property to the partner at the time of contribution, increased by the amount of any gain recognized under section 721(b) at the time. Sec. 722. Any increase in a partner’s share of liabilities of the partnership is considered a contribution by such partner to the partnership and increases the basis of the partner’s interest in the partnership. Sec. 752(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011