Section 704

Section 704 b of the internal revenue code provides that a partner s distributive share of income gain loss deduction or credit is determined in accordance with the partner s interest in the partnership if the partnership agreement does not provide as to the partner s distributive shares of these items or the allocation to a partner of these items under the agreement does not have substantial economic effect.

Section 704. Partner s distributive share on westlaw findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system. Section 704 c reporting is more common than most expect. Section 704 8 of the senate amendment is deleted in the house amendment.

704 a effect of partnership agreement a partner s distributive share of income gain loss deduction or credit shall except as otherwise provided in this chapter be determined by the partnership agreement. Income gain loss and deduction with respect to property contributed to the partnership by a partner shall be shared among the partners so as to take account of the variation between the basis of the property to the partnership and its fair market value at the time of contribution. Section 704 c layers relating to partnership mergers divisions and tiered partnerships notice 2009 70 section 1.

A preliminary procedural or intermediate agency action or ruling not directly reviewable is subject to review on the review of the final agency action except as otherwise expressly required by statute agency action otherwise final is final. 704 b determination of distributive share. For more detailed codes research information including annotations and citations please visit westlaw.

And under the general rules of section 704 when a partner contributes property to a partnership the partner s capital account is equal to the value of the property regardless of what the tax. While many may presume that section 704 c is a complex set of tax rules that only apply to specific or complex transactions it is key to remember that even a relatively straightforward transaction can create section 704 c attributes. Agency action made reviewable by statute and final agency action for which there is no other adequate remedy in a court are subject to judicial review.