Arlene Nussdorf, et al. - Page 20




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          tive members, with respect to which Evergreen Trading was re-               
          quired make certain determinations, are partnership items.                  
          Section 301.6231(a)(3)-1(a)(4), Proced. & Admin. Regs., states              
          that the following items, inter alia, which are required to be              
          taken into account under subtitle A of the Code, are more appro-            
          priately determined at the partnership level than at the partner            
          level and therefore are partnership items:15                                
                    (1) The partnership aggregate and each partner’s                  
               share of each of the following:                                        
                  *       *       *       *       *       *       *                   
                           (v) Partnership liabilities (including                     
                    determinations with respect to the amount of                      
                    the liabilities, whether the liabilities are                      
                    nonrecourse, and changes from the preceding                       
                    taxable year); * * *                                              
                  *       *       *       *       *       *       *                   
                    (4) Items relating to the following transactions,                 
               to the extent that a determination of such items can be                
               made from determinations that the partnership is re-                   
               quired 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 infor-                 
               mation to a partner:                                                   
                           (i) Contributions to the partnership * * *                 

               15Sec. 301.6231(a)(3)-1(b), Proced. & Admin. Regs., further            
          provides:                                                                   
                    (b) Factors that affect the determination of                      
               partnership items.-– The term “partnership item” in-                   
               cludes the accounting practices and the legal and                      
               factual determinations that underlie the determination                 
               of the amount, timing, and characterization of items of                
               income, credit, gain, loss, deduction, etc. * * *                      





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