swaitsandClaude Opus 5.5
6e6f9d65b2
check / check (push) Waiting to run
- core: TaxBasisRule (cost IRC 1012, carryover IRC 723, personal-use conversion Treas. Reg. 1.168(i)-4(b)), TaxBasis with the contributor's adjusted basis, Asset::tax_basis and ::built_in_gain (IRC 704(c)); the register gains tax rule, contributor basis, tax basis, built-in gain, total tax basis, missing count (rules.md B-25; sources vendored in docs/spec/sources/irs-partnership-basis.md) - store: asset.tax_basis_set journaled, replayed, projected (schema v10) - mcp: books.set_asset_tax_basis; register_asset takes tax_basis_rule and contributor_basis, checked before anything registers (found by the spec-blind suite); list_assets and the register export (json, csv) carry tax basis; instructions say to record it for every asset - import: the register's XLSX and PDF gain the federal tax basis table with citations - viewer: tax basis on the Assets page, the asset page (a Tax basis card), the report, the journal, and Needs attention for assets without one - just: check and the mutation recipes sweep this user's test book dirs older than an hour (killed runs had left 23 GB in RAM-backed /tmp) - docs: the parties, attachments, TIN vault, completeness engine, and updates designs (docs/parties-and-attachments.md) - tests: spec-blind tax basis suites in core, store, MCP; register PDF/XLSX and viewer tests Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com> Claude-Session: https://claude.ai/code/session_01GWVo7x3UHw5kwCUaWxiejX
41 lines
5.1 KiB
Markdown
41 lines
5.1 KiB
Markdown
# Tax basis of fixed assets: cost, contributed property, and personal-use conversion
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Governs the tax basis the fixed asset register carries beside book value (rules.md B-25). Property the partnership buys has a cost basis (IRC §1012); property a member contributes keeps the member's adjusted basis (IRC §723), and the difference from its fair market value is the built-in gain or loss that §704(c) makes the partnership account for; property a member converts from personal use has a depreciable basis of the lesser of fair market value and adjusted basis (Treas. Reg. §1.168(i)-4(b)(1)). wanderbooks records the basis; tax depreciation (MACRS, conventions, elections) stays with the CPA.
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## 26 U.S.C. §1012(a): basis is cost
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Source: <https://www.law.cornell.edu/uscode/text/26/1012>
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Retrieved: 2026-10-15
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SHA-256 of the retrieved file (`usc1012.html`): `831c9a6a91fceb2f78968520b6f7811b0975bdc170538fa333baa072b799990b`
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> The basis of property shall be the cost of such property, except as otherwise provided in this subchapter and subchapters C (relating to corporate distributions and adjustments), K (relating to partners and partnerships), and P (relating to capital gains and losses).
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## 26 U.S.C. §723: basis of property contributed to a partnership
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Source: <https://www.law.cornell.edu/uscode/text/26/723>
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Retrieved: 2026-10-15
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SHA-256 of the retrieved file (`usc723.html`): `bfc8c78b5ef5e230f8df1c76d8ab3020ea4a515d987576bba37e740bb5c8c4c7`
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> The basis of property contributed to a partnership by a partner shall be the adjusted basis of such property to the contributing partner at the time of the contribution increased by the amount (if any) of gain recognized under section 721(b) to the contributing partner at such time.
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## 26 U.S.C. §704(c)(1): built-in gain and loss on contributed property
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Source: <https://www.law.cornell.edu/uscode/text/26/704>
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Retrieved: 2026-10-15
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SHA-256 of the retrieved file (`usc704.html`): `03a2c2fd087cc5e849f3755417e34bf8d869afc67e4650f5473a4e73b7cec099`
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**§704(c)(1)(A): the variation between basis and fair market value**
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> income, gain, loss, and deduction with respect to property contributed to the partnership by a partner shall be shared among the partners so as to take account of the variation between the basis of the property to the partnership and its fair market value at the time of contribution,
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**§704(c)(1)(C)**
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> if any property so contributed has a built-in loss — (i) such built-in loss shall be taken into account only in determining the amount of items allocated to the contributing partner, and (ii) except as provided in regulations, in determining the amount of items allocated to other partners, the basis of the contributed property in the hands of the partnership shall be treated as being equal to its fair market value at the time of contribution.
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**Built-in loss, defined**
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> For purposes of subparagraph (C), the term “built-in loss” means the excess of the adjusted basis of the property (determined without regard to subparagraph (C)(ii)) over its fair market value at the time of contribution.
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## Treas. Reg. §1.168(i)-4(b)(1): conversion from personal to business use
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Source: <https://www.ecfr.gov/api/renderer/v1/content/enhanced/current/title-26?part=1§ion=1.168(i)-4>
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Retrieved: 2026-10-15
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SHA-256 of the retrieved file (`ecfr168i4.html`): `284efb83eeb11442ab86e050f6d630bd468fd75463e27e3ec81dbc8de455e9be`
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> Depreciation deduction allowable. This paragraph (b) applies to property that is converted from personal use to use in a taxpayer's trade or business, or for the production of income, during a taxable year. This conversion includes property that was previously used by the taxpayer for personal purposes, including real property (other than land) that is acquired before 1987 and converted from personal use to business or income-producing use after 1986, and depreciable property that was previously used by a tax-exempt entity before the entity changed to a taxable entity. Except as otherwise provided by the Internal Revenue Code or regulations under the Internal Revenue Code, upon a conversion to business or income-producing use, the depreciation allowance for the year of change and any subsequent taxable year is determined as though the property is placed in service by the taxpayer on the date on which the conversion occurs. Thus, except as otherwise provided by the Internal Revenue Code or regulations under the Internal Revenue Code, the taxpayer must use any applicable depreciation method, recovery period, and convention prescribed under section 168 for the property in the year of change, consistent with any election made under section 168 by the taxpayer for that year (see, for example, section 168(b)(5)). See §§ 1.168(k)-1(f)(6)(iii) or 1.168(k)-2(g)(6)(iii), as applicable, and 1.1400L(b)-1(f)(6) for the additional first year depreciation deduction rules applicable to a conversion to business or income-producing use. The depreciable basis of the property for the year of change is the lesser of its fair market value or its adjusted depreciable basis (as defined in § 1.168(b)-1T(a)(4)), as applicable, at the time of the conversion to business or income-producing use.
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