TITLE 26. INTERNAL REVENUE CODE § 704. Partner’s distributive share., 26 USCS § 704


Summary

(a) Effect of partnership agreement. A partner’s distributive share of income, gain, loss, deduction, or credit shall, except as otherwise provided in this chapter [26 USCS §§ 1 et seq.], be determined by the partnership agreement.
(b) Determination of distributive share. A partner’s distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined in accordance with the partner’s interest in the partnership (determined by taking into account all facts and circumstances), if—
(1) the partnership agreement does not provide as to the partner’s distributive share of income, gain, loss, deduction, or credit (or item thereof), or
(2) the allocation to a partner under the agreement of income, gain, loss, deduction, or credit (or item thereof) does not have substantial economic effect.
(c) Contributed property.
(1) In general. Under regulations prescribed by the Secretary—
(A) income, gain, loss, and deduction with respect to property contributed to the partnership by a ...