§ 773. Computations at partnership level
(a)
General rule
(1)
Taxable income
The taxable income of an electing large partnership shall be computed in the same manner as in the case of an individual except that—
(2)
Elections
All elections affecting the computation of the taxable income of an electing large partnership or the computation of any credit of an electing large partnership shall be made by the partnership; except that the election under section
901, and any election under section
108, shall be made by each partner separately.
(3)
Limitations, etc.
(A)
In general
Except as provided in subparagraph (B), all limitations and other provisions affecting the computation of the taxable income of an electing large partnership or the computation of any credit of an electing large partnership shall be applied at the partnership level (and not at the partner level).
(b)
Modifications to determination of taxable income
In determining the taxable income of an electing large partnership—
(1)
Certain deductions not allowed
The following deductions shall not be allowed:
(C)
The additional itemized deductions for individuals provided in part VII of subchapter B (other than section
212 thereof).
(3)
Coordination with section
67
In lieu of applying section
67,
70 percent of the amount of the miscellaneous itemized deductions shall be disallowed.
(c)
Special rules for income from discharge of indebtedness
If an electing large partnership has income from the discharge of any indebtedness—