Partnership basis (outside and inside)

A partner's outside basis starts with cash plus the adjusted basis of contributed property, rises with income and the partner's share of partnership liabilities, falls with distributions, losses and liability relief, and cannot go below zero; a deemed distribution in excess of basis is gain.

Updated 2026-09-23 · 3 sources · By the EnrolledAgentKit team
Exam part
Part 2
Businesses
IRS domain
Business Entities and Considerations
30 of 85 scored Qs
Tax year tested
2025
2026-27 SEE
Practice questions
13
10 free below

The rules the exam tests

Figures for tax year 2025, the year the 2026-27 SEE tests. Verify against the cited primary source.
RuleWhat it says (2025)Source
Initial basisCash + adjusted basis of property contributed (+ gain recognized)IRC 722
LiabilitiesIncrease in share = cash contribution; decrease = cash distributionIRC 752
IncreasesShare of taxable and tax-exempt incomeIRC 705(a)(1)
DecreasesDistributions, share of losses and nondeductible expensesIRC 705(a)(2)
Current cash distribution > basisGain (generally capital)IRC 731(a)
Property distribution basisLesser of partnership basis or partner's outside basisIRC 732(a)
Liquidating lossOnly if receiving just cash, receivables and inventoryIRC 731(a)(2)
Loss limitBasis, then at-risk, passive and excess business loss rulesIRC 704(d)
Partnership's (inside) basis in contributed propertyCarryover from partnerIRC 723
Worked example

Facts: Bill contributes a building (basis $50,000, FMV $120,000) subject to an $80,000 mortgage for a 25% interest; the partnership assumes the mortgage.

Outside basis: $50,000 - $80,000 relieved + 25% x $80,000 = -$10,000, so basis is $0 and Bill recognizes $10,000 gain under IRC 731. The partnership’s inside basis in the building is $50,000.

Exam traps

  • Liability relief is a deemed cash distribution.
  • Guaranteed payments are ordinary income and SE income; they are not distributions.
  • A capital interest received for services is ordinary income at FMV.
  • Section 754 adjusts inside basis; it does not change outside basis.

Partnership basis (outside and inside): 10 free practice questions

Partnership basis (outside and inside) practice questions

A partner contributes $10,000 cash and land with an adjusted basis of $15,000 (FMV $25,000) to a partnership. There are no liabilities. What is the partner's initial outside basis?

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Frequently asked questions

What increases a partner's basis?

Contributions, the partner’s share of income (including tax-exempt income) and increases in the partner’s share of partnership liabilities.

Can partnership basis go negative?

No. Distributions or liability relief beyond basis trigger gain instead.

Sources

  1. IRS Publication 541 - Partnerships (accessed 2026-09-23)
  2. IRS - SEE Part 2 content specifications (Businesses) (accessed 2026-09-23)
  3. IRS - Enrolled agents: Frequently asked questions (accessed 2026-09-23)