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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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Last modified: November 10, 2007