mneath
Level 1
12-06-2019
09:08 PM
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The only reason that charitable deductions are flow through items on the K-1 is so that the AGI limit can be applied at the individual level. But for that, it would just be a normal business expense and reflected in a reduction of box 1 income on the K-1. Doesn't that mean that it is "a deduction . . .with respect to any trade or business of the taxpayer" (Reg. 1.199A3(b)(1))?