Files
wanderbooks/docs/spec/sources/irs-partnerships.md
T
swaitsandClaude Opus 5.5 ad572ae89d docs(spec): every rule traced to an authority; public-domain sources vendored
Stephen asked that specs come from recognized documents, not from
anyone's memory. There is no single US bookkeeping bible; authority is
layered, and this records it:

- docs/spec/sources/: verbatim excerpts (whitespace normalized), each
  with URL, retrieval date, and the SHA-256 of the fetched file, of
  public-domain texts: Pacioli's 1494 treatise in Geijsbeek's 1914
  translation (double entry, the trial balance, one money, write only
  forward, correct by opposite entry, close into capital); IRS Pub. 583,
  538, 946, 15; the 1099-MISC/NEC instructions (2025 and 2026); 26 U.S.C.
  §6041, §6041A, §704; Treas. Reg. §1.263(a)-1(f) and -4(f); Notice
  2015-82; Rev. Proc. 98-25; Form 1065 instructions; 17 U.S.C. §105. The
  excerpts were extracted by matching each passage against the fetched
  file, so none can contain text the source doesn't.
- docs/spec/rules.md: the rule catalog, B-1 to B-22. Each rule says
  AUTHORITY, CONVENTION, or DECISION; cites its sources (FASB's
  Codification and Concepts Statement 8 and OpenStax quoted briefly,
  never copied: copyright and CC BY-NC-SA); and names the code that
  enforces it and the tests and proofs that check it.
- Spec blocks in the code now carry SOURCE: lines into the catalog;
  AGENTS.md makes sourcing rule 0 of the formal-methods bar.

Corrections the sources turned up: the de minimis limit is $500 in the
regulation and $2,500 by Notice 2015-82 (both now cited); 1099
thresholds after 2026 are inflation-indexed, so the engine's flat
$2,000 for 2027+ is an open question (B-19). Unverified ASC paragraphs
(360-10-35-4, 340-10, 230-10-45-10, 606-10-55-37B, 210) are listed in
docs/spec/README.md until someone with a FASB basic-view login reads
them.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Claude-Session: https://claude.ai/code/session_01GWVo7x3UHw5kwCUaWxiejX
2026-10-13 12:18:57 -06:00

2.0 KiB
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Partnerships: shares of income and capital accounts

Governs CloseTo::Members and the members' equity statement. Partners' shares come from the partnership agreement (IRC §704(a)); Form 1065 reports each partner's capital account (Schedule K-1 item L) and the changes in them (Schedule M-2). No authority prescribes how to round a share to the cent: that rule is Stephen's decision (largest remainder, 2026-10-13).

26 U.S.C. §704(a)-(b)

Source: https://www.law.cornell.edu/uscode/text/26/704
Retrieved: 2026-10-13
SHA-256 of the retrieved file (usc704.txt): e596d36039cb451fe9c5bef5eb6b4c36d2451ab83b06e642a8bf44f3697cf3ee

A partner’s distributive share of income, gain, loss, deduction, or credit shall, except as otherwise provided in this chapter, be determined by the partnership agreement.

Instructions for Form 1065 (2025)

Source: https://www.irs.gov/instructions/i1065
Retrieved: 2026-10-13
SHA-256 of the retrieved file (i1065.txt): 364ec05f6a688447def50169604ec0aa976edb2532b110e2736759213a02da78

Allocating among partners

Allocate shares of income, gain, loss, deduction, or credit among the partners according to the partnership agreement for sharing income or loss generally.

Schedule M-2

Show what caused changes during the tax year in the partners’ tax-basis capital accounts.

Rounding on the return (not in the books)

The partnership may enter decimal points and cents when preparing its return. However, it should round off cents to whole dollars on its return, forms, and schedules to make completing its return easier. The partnership must either round off all amounts on the return to whole dollars, or use cents for all amounts. To round, drop amounts under 50 cents and increase amounts from 50 to 99 cents to the next dollar. For example, $8.40 rounds to $8 and $8.50 rounds to $9. If two or more amounts are added to figure the amount to enter on a line, include cents when adding the amounts and round off only the total.