- 119 - deficiency for 1989 and 1990. For those years, the treatment of Zephyr’s liabilities was an S corporation item, to be determined at the corporate level. See sec. 301.6245-1T(a)(5), Temporary Income Tax Regs., 52 Fed. Reg. 3003 (Jan. 30, 1987). (For years beginning after December 31, 1996, these procedures do not apply. See Small Business Job Protection Act of 1996, Pub. L. 104-188, 110 Stat. 1755.) Because no notice of administrative adjustment (FSAA) was issued to Zephyr, the nature of the transfers as reported by Zephyr cannot be redetermined here. Issues #4 and #5–-Partners’ Basis in PKVI LP Generally, a partner may deduct the partner’s distributive share of losses of a partnership in which the partner is a member. Sec. 702(a). A partner’s distributive share of partnership loss is limited to the extent of the adjusted basis (before reduction by current year’s losses) of the partner’s interest in the partnership at the end of the partnership year in which such loss occurred. Sec. 704(d); sec. 1.704-1(d)(1), Income Tax Regs. A partner’s share of loss in excess of the partner’s adjusted basis at the end of the partnership year will not be allowed for that year. Sec. 1.704-1(d)(1), Income Tax Regs. Any excess of such loss over such basis shall be allowed as a deduction at the end of the partnership year in which such excess is repaid to the partnership. Sec. 704(d); see also sec. 1.704-1(d)(1), Income Tax Regs. (“[A]ny loss so disallowed shallPage: Previous 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 Next
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