- 20 - 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. * * *Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: November 10, 2007