The rules the exam tests
| Rule | What it says (2025) | Source |
|---|---|---|
| Initial basis | Cash + adjusted basis of property contributed (+ gain recognized) | IRC 722 |
| Liabilities | Increase in share = cash contribution; decrease = cash distribution | IRC 752 |
| Increases | Share of taxable and tax-exempt income | IRC 705(a)(1) |
| Decreases | Distributions, share of losses and nondeductible expenses | IRC 705(a)(2) |
| Current cash distribution > basis | Gain (generally capital) | IRC 731(a) |
| Property distribution basis | Lesser of partnership basis or partner's outside basis | IRC 732(a) |
| Liquidating loss | Only if receiving just cash, receivables and inventory | IRC 731(a)(2) |
| Loss limit | Basis, then at-risk, passive and excess business loss rules | IRC 704(d) |
| Partnership's (inside) basis in contributed property | Carryover from partner | IRC 723 |
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
Drill every Part 2 topic
The full bank has 300 original Part 2 questions (900 across all parts) weighted to the IRS domains. $149 once, free extension until you pass.
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
- IRS Publication 541 - Partnerships (accessed 2026-09-23)
- IRS - SEE Part 2 content specifications (Businesses) (accessed 2026-09-23)
- IRS - Enrolled agents: Frequently asked questions (accessed 2026-09-23)