Partnership Item

ID: CCA_2009052715074137 Number: 200928934
Release Date: 7/10/2009
Office: ---
UILC: 6231.03-00
From: ---
Sent: Wednesday, May 27, 2009 3:07:42 PM
To: ---
Cc: ---
Subject: RE: PAL
Under Estate of Quick v. Commissioner, the classification and grouping of the passive activity engaged in by the partnership is a partnership item determined at the partnership level and reported on the partnership return. The Schedule K-1 is part of the partnership return, so that it can be reported there.
The Forms k-1 issued to the partners should reflect each partners share of the income/loss from each separate grouped activity, e.g., rental activity, other trade or business or portfolio activity.