Partnership Item

ID: CCA_2011022213581237 Number: 201112020
Release Date: 3/25/2011
Office: ---
UILC: 6231.03-00
From: ---
Sent: Tuesday, February 22, 2011 1:58:20 PM
To: ---
Cc: ---
Subject: RE: Tefra Question - ---
A payment from a partnership to a partner other than in the partner's capacity as a partner (under section 707) is a partnership item under Treas. Reg. 301.6231(a)(3)-1(a(2)(iii) and 301.6231(a)(3)-1(c)(4). An affected item would be limited to things such as the cost of goods a partner sold to the partnership. But the gross payments between a partnership and partner (as in your case) would be partnership items.