-110- contributing partner’s adjusted basis in the property at the time of the contribution. Sec. 723. Each partner’s proportionate share of the partnership’s basis in its property is referred to as “inside basis.” Cf. Gindes v. United States, 228 Ct. Cl. 632, 661 F.2d 194, 197 n.9 (1981). Under section 704(c)(1)(A), items of income, gain, loss, and deduction with respect to property contributed to a partnership by a partner are specially allocated among the partners so as to take account of any variation between the partnership’s basis in the contributed property and its fair market value at the time of contribution (this variation is sometimes referred to as built-in gain or loss). See sec. 1.704-3, Income Tax Regs. (providing special rules for allocating items between noncontributing and contributing partners). This rule is generally designed to prevent transfers of built-in gain or loss from the contributing partner to the other partners. If the contributing partner transfers his partnership interest, built-in gain or loss must be allocated to the transferee partner as it would have been allocated to the transferor partner. Sec. 1.704-3(a)(7), Income Tax Regs. If the partnership has made a one-time election under section 754, adjustments are made with respect to the transferee partner’s inside basis, essentially so as to approximate the result of a direct purchase of the property by the transfereePage: Previous 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 Next
Last modified: May 25, 2011