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Table 4. Summary Statistics for 1983 Partnerships by Year Partnership was formed.

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N (1) Was there a distribution of property or a transfer of a partnership interest during the tax year?

(2) If "Yes," is the partnership making an election under section 754? "Yes," attach a statement for the election. (See page 4 of the Instructions before answering this question.)

O At any time during the tax year, did the partnership have an interest in e signature or other authority over a bank account, securities account, other financial account in a foreign country (me page 4 of instructions)? P Was the partnership the grantor of, or transferor to, a foreign trust which existed during the current tax your, whether or not the partnership or any partner has any beneficial interest in it? If "Yes," may have to file Forms 3520, 3520-4, or 926. (See page 5 of last QAre there any specially allocated items of incar credit, etc. (see page 5 of Instructions).

16 Minus returns and allowances S

2

3

Cost of goods sold and/or operations (Schedule A, line 7) Gross profit (subtract line 2 from line 1c).

4

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Ordinary income (loss) from other partnerships and fiduciaries

Nonqualifying interest and nonqualifying dividends
Gross rents $..

ass, deduction,

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Yes No

6 Minus rental expenses (attach schedule

с

Balance net rental income (loss)

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7

Net income (loss) from royalties (attach schedule)

7

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Net farm profit (loss) (attach Schedule F (Form 1040))

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Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief it is true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.

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Form 1065 (1983)

SCHEDULE A.-Cost of Goods Sold and/or Operations (See Page 7 of Instructions.)

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Page 2

Inventory at end of year.

7 Cost of goods sold (subtract line 6 from line 5) Enter here and on page 1, line 2

Sa Check all methods used for valuing closing inventory.

(1)Cost

()Lower of cost or market as described in regulations section 1.471-4 (see page 8 of Instructions)

(H) (lv)

Writedown of "subnormal" goods as described in regulations section: 1.471-2(c) (see page 8 of Instructions)
Other (specify method used and attach explanation)►

b Check if the LIFO inventory method was adopted this tax year for any goods (if checked, attach Form 970)

If you are engaged in manufacturing, did you value your inventory using the full absorption method (regulations section 1.471-11)? d Was there any substantial change in determining quantities, cost, or valuations between opening and closing inventory?. If "Yes." attach explanation.

SCHEDULE B.-Distributive Share Items (See Pages 8, 10-11, and 15 of Instructions.)

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Credits

Deductions

Income (Loss)

SCHEDULE K
(Form 1065)

Department of the Treasury
Internal Revenue Service

Name of partnership

Partners' Shares of Income, Credits, Deductions, etc.

►Flie this form if there are more than ten Schedules K-1 to be filed with Form 1065.
Do not complete lines 6, 8, 21h, and 21c. The amounts for these lines are shown on Schedule 8, Form 1065.
►Attach to Form 1065.
See Instructions for Schedule K (Form 1065).

OMB No. 1545-0099

1983

Employer Identification number

a. Distributive share items

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11 Expense deduction for recovery property (section 179) from Part I, Section A, Form 4562

11

12a

12a Payments for partners to an IRA

12b

b Payments for partners to a Keogh Plan (Type of plan

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Investment Interest Tax Preference Items Other

19a Accelerated depreciation on nonrecovery real property or 15-year real property.

19a

⚫ Accelerated depreciation on leased personal property or leased recovery property other than
15-year real property

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Excess of net long-term capital gain over net short-term capital loss from investment property 20d 21a Type of income......

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b. Total amount

Chairman PICKLE. Mr. Pearlman, you have given us very important, if not startling information. I think the committee and the members will want to analyze and study your statements as well as the charts you include.

If these facts are exactly analyzed, I think we would come to the conclusion it is not right that a large number of very high taxpayers are paying virtually no tax. Now we need to look for some ways to correct that.

Now, first I want to ask you some general questions.

In your opinion, the public's perception of whether our current tax system is fair-has it improved in recent years, or has it deteriorated?

Mr. PEARLMAN. My judgment, and I think that the analyses that have been conducted, including the recent analysis that was commissioned by the Internal Revenue Service in late 1984, I believe would indicate that the perception of fairness over a period of years has gone down, not up.

Now, I can't tell you that the perception of fairness between 1982-83 has changed, but I think there is a trend, a documented trend through the work that has been done by outsiders, not by the Government, that would indicate the perception of unfairness has increased.

Chairman PICKLE. We have a minimum tax now for an individual. How is it possible then that 55,000 high income persons were able to pay little or no taxes?

This raises a question.

Is the current individual minimum tax operating effectively?
If it is, for whom?

Or what do we do about it?

What is your judgment about the minimum tax at this point?

Mr. PEARLMAN. Let me just take the liberty here of referring to the President's proposals. I won't refer to them specifically, but I think the current minimum tax does not operate effectively, and I think there are some changes appropriate in the minimum tax to try to deal with that issue.

We have sought to do that. We have made specific recommendations in terms of changes in the minimum tax.

Chairman PICKLE. I am not going to go into the question of the total positive income, because you have gone into it in some detail. This had been raised by some members as being an unfair meas

urement.

I suppose it works both ways.

What other system would you use, the AGI system?

Do you want to add anything to that?

I don't want to get into a discussion, except to recognize some people who feel that is not a fair measurement.

Mr. PEARLMAN. We can't use AGI. By the time you get to AGI on the tax return many tax shelter losses have already been taken out of the calculations. So if we begin with AGI it is impossible to make that calculation.

There are other approaches in the materials that the Joint Committee prepared for the Ways and Means Committee in connection with the fundamental tax reform analysis. One of the pamphlets

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