Partnership Item

ID: CCA_2011120208294737 Number: 201149030
Release Date: 12/9/2011
Office: ---
UILC: 6231.03-00
From: ---
Sent: Friday, December 02, 2011 8:30:02 AM
To: ---
Cc: ---
Subject: RE: TEFRA and Self-Employment Tax
Under Olsen-Smith v. Commissioner, T.C. Memo. 2005-174, the allocation and gross amount of trade or business income potentially subject to self-employment tax is determined at the partnership level but not its ultimate taxability which would be determined following the partnership proceeding by aggregating all self-employment income. Thus, in your TEFRA partnership proceeding you should determine the amount of self-employment income allocable to each partner.