Can a general partner deduct Investment Interest on Schedule C?

[wrightlj]

My client is designated as one of two General Partners in a partnership.  His 1065 K-1 for 2021, Line 13, Code H shows a large Investment Interest Expense amount.  

Can he deduct this interest on Schedule C instead of Schedule A?  Is the General Partner designation sufficient to justify that?

If deducted on Schedule C, there would be a significant tax savings over Schedule A, both federal and state.  

Thank you!

[sjrcpa]

What relationship does the Schedule C have to the General Partnership?

Off hand, No. The investment interest goes on 4952/Sch A.

[wrightlj · Accepted solution]

Thanks for the reply-

Client does have other self-employment income which we report on Schedule C - he is an Investment Manager for several clients.

He is/has been a general partner in a few other partnerships over the last 20 years. In some cases, he is paid an annual management fee, reported to him on K-1 on Line 4a - Guaranteed Payments for Services and on Line 14, Code A, as self-employment income.  

Those amounts flow to Schedule SE, where it is combined with other self-employment income/loss to arrive at self-employment tax.    

Those management fees are self-employment income and if he were paid a fee by this partnership, the same would be true.  I guess that's the relationship.   

The instructions for Form 4952, p3, Part III, Line 8 state, after saying it goes to Sched A or E, adds, "Also, if any part of the interest is attributable to a trade or business that isn't a passive activity, enter that part on the schedule where you report other expenses for that trade or business".   The only other income or expense there's ever been from this partnership is a bit of interest income.  

As I write all this, it's becoming clearer to me why my thought doesn't fly.  I appreciate your assistance as I suss this out.