26 U.S.C. § 722
Section 722 · Basis of contributing partners interest
Amended 3 times on record
Applied in 226 court decisions — leading case United States v. Koppers Co. (1955)
Most recently applied in 416 U.S. App. D.C. 411 - Petaluma FX Partners, LLC v. Commissioner of IRS (June 2015)
Cases citing this section usually also cite 26 U.S.C. § 732 · 26 U.S.C. § 6662 · 26 U.S.C. § 752
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The basis of an interest in a partnership acquired by a contribution of property, including money, to the partnership shall be the amount of such money and 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.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1984—Pub. L. 98–369 inserted “under section 721(b)” after “gain recognized”.
1976—Pub. L. 94–455 inserted “increased by the amount (if any) of gain recognized to the contributing partner at such time” after “at the time of the contribution”.
Effective Date of 1984 Amendment
Section 722(f)(2) of Pub. L. 98–369 provided that: “The amendments made by paragraph (1) [amending this section and section 723 of this title] shall take effect as if included in the amendments made by section 2131 of the Tax Reform Act of 1976 [Pub. L. 94–455].”
Effective Date of 1976 Amendment
For effective date of amendment made by Pub. L. 94–455, see section 2131(f)(3)–(5) of Pub. L. 94–455, set out as a note under section 721 of this title.
Cross References
Determination of basis of partner's interest, see section 705 of this title.