§742 — Basis of transferee partner’s interest

Alternatively, section 742 provides that the “basis of an interest in a partnership acquired other than by contribution shall be determined under part II of subchapter O (sec.

It provides that the adjusted basis of a partner’s interest shall be the basis determined under section 722 or section 742, increased or decreased by certain amounts (including the partner’s distributive share of partnership income and losses).

742 provides: “The basis of an interest in a partnership acquired other than by contribution shall be determined under part II of subchapter O (sec. 1011 and following).” In general, the basis of property acquired by gift is the same as it was in the hands of the donor. Sec. 1015. For purposes of determining loss, however, if that basis is gre

§§ 705(a)(2), 733; see also Treas.

The adjusted basis ofa partner's interest in a partnership is determined under section 722 (relating to contributions to a partnership) or section 742 (relating to transfers ofpartnership interests) increased by his distributive share ofpartnership taxable income (plus any exempt income and excess depletion deductions).

The adjusted basis ofa partner's interest in a partnership is determined under section 722 (relating to contributions to a partnership) or section 742 (relating to transfers ofpartnership interests) increased by his distributive share ofpartnership taxable income (plus any exempt income and excess depletion deductions).

Petitioners characterize Steven's payments as "acquisition costs" and con- tend that they generate basis under section 742, which provides that "[t]he basis of an interest in a partnership acquired other than by contribution" shall be deter- mined under the Code's general basis rules.

The adjusted basis ofa partner's interest in a partnership is determined under section 722 (relating to contributions to a partnership) or section 742 (relating to transfers ofpartnership interests) increased by his distributive share ofpartnership taxable income (plus any exempt income and excess depletion deductions).

In relevant part, section 705(a) provides that the adjusted basis ofa partner's interest in a partnership is his original basis as determined under section 722 (relating to contributions to a partnership) or section 742 (relating to transfers ofpartnership interests) increased by (1) the amount of money and his basis in property subsequently contributed to the partnership and (2) his distributable share ofthe income ofthe partnership and decreased (but not below zero) by (1) the amount ofmoney a

In relevant part, section 705(a) provides that the adjusted basis of a partner’s interest in a partnership is his original basis as determined under section 722 (relating to contributions to a partnership) or section 742 (relating to transfers of partnership interests) increased by (1) the amount of money and his basis in property subsequently contributed to the partnership and (2) his distributable share of the income of the partnership and decreased (but not below zero) by (1) the amount of mo

Section 722 provides that the basis of an interest in a F .

rn for the 1995 tax year, in the case of qualifying children born after Oct. 1, 1995. For a return for the 1996 tax year, the requirement is waived for qualifying children born after Nov. 30, 1996. See Uruguay Round Agreements Act, Pub. L. 103-465, sec. 742(c)(2), 108 Stat. 5010 (1994). - 8 - Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206, sec. 6021(b)(3), 112 Stat. 823. As part of this amendment, section 32(c)(3)(A)(iv) was stricken from the statute. In addition to ame

a tax return has significantly reduced the improper claiming of dependents. Requiring that TIN’s be supplied regardless of the age of the dependent will further reduce the improper claiming of dependents. [H. Rept. 103-826, at 196 (1994) (discussing sec. 742(b) of the Uruguay Round Agreements Act, Pub. L. 103-465, 108 Stat. 4809, 5010 (1994)).] The use of SSN’s also helps ensure that there is indeed a person in existence to support the claimed exemption. See U.S. General Accounting Office, Tax A

742 (Basis of Transferee Partner’s Interest), sec. 743 (Optional Adjustment to Basis of Partnership Property). Outside of subchapter K, whether the aggregate or the entity approach is to be applied depends upon which approach more appropriately serves the Code provision at issue. See Holiday Village Shopping Ctr. v. United States, 773 F.2d 276

rn for the year. See Miller v. Commissioner, supra at ___ (slip op. at 9-10). Congress acknowledged this benefit in 1994, when it eliminated an exception to the TIN requirement. See sec. 6109 as amended by Uruguay Round Agreements, Pub. L. 103-465, sec. 742, 108 Stat. 5010 (1994). The House report discussing this section states: The requirement that TIN’s be provided with respect to each dependent claimed on a tax return has signi- ficantly reduced the improper claiming of dependents. Requiring

742 (Basis of Transferee Partner’s Interest) and sec. 743 (Optional Adjustment to Basis of Partnership Property). Outside of subchapter K, whether the aggregate or the entity approach is to be applied depends upon which approach more appropriately serves the Code provision at issue. See Holiday Village Shopping Ctr. v. United States, 773 F.2d

- 7 - In 1993, section 742.30(C) was added to the Ohio Revised Code which provided: (C) The board of trustees of the police and firemen's disability and pension fund may enter into an agreement with a municipal corporation for a single payment by the municipal corporation of the employer's accrued liability.