PK Ventures, Inc. and Subsidiaries, et al. - Page 31

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          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 shall            






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