§ 702. Income and credits of partner
(a)
General rule
In determining his income tax, each partner shall take into account separately his distributive share of the partnership’s—
(3)
gains and losses from sales or exchanges of property described in section
1231 (relating to certain property used in a trade or business and involuntary conversions),
(6)
taxes, described in section
901, paid or accrued to foreign countries and to possessions of the United States,
(b)
Character of items constituting distributive share
The character of any item of income, gain, loss, deduction, or credit included in a partner’s distributive share under paragraphs (1) through (7) of subsection (a) shall be determined as if such item were realized directly from the source from which realized by the partnership, or incurred in the same manner as incurred by the partnership.
(c)
Gross income of a partner
In any case where it is necessary to determine the gross income of a partner for purposes of this title, such amount shall include his distributive share of the gross income of the partnership.
(d)
Cross reference
For rules relating to procedures for determining the tax treatment of partnership items see subchapter C of chapter 63 (section
6221 and following).