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Old 04-07-2005, 05:57 AM
Thomas Healy
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Default Re: "technical termination" of limited partnership - passive

"Jeff" <jeff.h[at]bigfoot.com> wrote:

- quote -

> I'm stumped.
> Client bought shares of a Star Gas publicly traded limited
> partnership. The partnership had a "technical termination"
> because of turnover of shares in November, so he got two
> K-1s. 1/1-11/30 shows a loss, the one for December shows a
> gain. Instructions say to treat as two separate investments,
> so I entered that way. It looks like the passive loss in
> unallowable and the gain is taxable.
> Logical; BUT the "old" partnership really terminated on
> 11/30, so shouldt I terminate that investment and take the
> loss? Or do I roll the whole deferred unallowable losses
> into the new investment, thereby offsetting the taxability
> of the new income?
> In addition to the tax question, if someone has an answer,
> do you know how I get that answer into Lacerte?


Mark the "old" investment as a complete disposition of a
passive activity. Make sure to include the ordinary income
recapture and the proper statements regarding disposition in
the return (hopefully the K-1 and supplemental materials
identify this). The "new" K-1 should show a capital
contribution equal to the distribution in the "old" K-1
(less distributions earlier in the year).

--
Tom Healy, CPA
Boulder, CO
Web: http://www.tomhealycpa.com

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Old 04-05-2005, 09:31 AM
Jeff
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Posts: n/a
Default "technical termination" of limited partnership - passive losses

I'm stumped.

Client bought shares of a Star Gas publicly traded limited
partnership. The partnership had a "technical termination"
because of turnover of shares in November, so he got two
K-1s. 1/1-11/30 shows a loss, the one for December shows a
gain. Instructions say to treat as two separate investments,
so I entered that way. It looks like the passive loss in
unallowable and the gain is taxable.

Logical; BUT the "old" partnership really terminated on
11/30, so shouldt I terminate that investment and take the
loss? Or do I roll the whole deferred unallowable losses
into the new investment, thereby offsetting the taxability
of the new income?

In addition to the tax question, if someone has an answer,
do you know how I get that answer into Lacerte?

Thanks

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
 

Tags
limited, losses, partnership, passive, technical termination
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