Guide

For purposes of answering Schedule B questions 3a and 3b what percentage interest does the Partnership report as being owned by individual partners A and B and revocable grantor trusts T1 and T2 unde

T1 and T2 each own 50 percent of the profit, loss, and capital of partnership X.
A owns 100 percent of revocable grantor trust T1.
B owns 100 percent of revocable grantor trust T2. B is A’s wife.

A9: Assuming that T1 and T2 are required to file returns for federal income tax purposes, partnership X reports revocable grantor trusts T1 and T2 on question 3a and shows each as owning, directly or indirectly, 50 percent of the profit, loss, or capital of partnership X.

Partnership X reports in repose to question 3b that A owns, directly or indirectly, 100 percent of the profit, loss, or capital of partnership X. For these purposes, A is considered to own 50 percent indirectly through revocable grantor trust T1 and also to own 50 percent through family attribution from his wife, B.

Partnership X also reports in response to question 3b that B owns, directly or indirectly, 100 percent of the profit, loss, or capital of partnership X. B owns 50 percent indirectly through revocable grantor trust T2 and 50 percent through family attribution from her husband, A.

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