Title 26Internal Revenue CodeRelease 119-73

§703 Partnership computations

Title 26 › Subtitle Subtitle A— - Income Taxes › Chapter CHAPTER 1— - NORMAL TAXES AND SURTAXES › Subchapter Subchapter K— - Partners and Partnerships › Part PART I— - DETERMINATION OF TAX LIABILITY › § 703

Last updated Apr 6, 2026|Official source

Summary

Partnerships must figure their taxable income the same way a person does, but with some differences. Certain partnership items must be shown separately. The partnership cannot take deductions for personal exemptions, foreign taxes paid to other countries or U.S. possessions, charitable gifts, net operating losses, certain extra individual itemized deductions, or depletion for oil and gas wells. Most tax elections about how to compute partnership income must be made by the partnership, except for three specific elections dealing with discharged debt, certain mining exploration costs, and foreign taxes.

Full Legal Text

Title 26, §703

Internal Revenue Code — Source: USLM XML via OLRC

(a)The taxable income of a partnership shall be computed in the same manner as in the case of an individual except that—
(1)the items described in section 702(a) shall be separately stated, and
(2)the following deductions shall not be allowed to the partnership:
(A)the deductions for personal exemptions provided in section 151,
(B)the deduction for taxes provided in section 164(a) with respect to taxes, described in section 901, paid or accrued to foreign countries and to possessions of the United States,
(C)the deduction for charitable contributions provided in section 170,
(D)the net operating loss deduction provided in section 172,
(E)the additional itemized deductions for individuals provided in part VII of subchapter B (sec. 211 and following), and
(F)the deduction for depletion under section 611 with respect to oil and gas wells.
(b)Any election affecting the computation of taxable income derived from a partnership shall be made by the partnership, except that any election under—
(1)subsection (b)(5) or (c)(3) of section 108 (relating to income from discharge of indebtedness),
(2)section 617 (relating to deduction and recapture of certain mining exploration expenditures), or
(3)section 901 (relating to taxes of foreign countries and possessions of the United States),

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1993—Subsec. (b)(1). Pub. L. 103–66 substituted “subsection (b)(5) or (c)(3)” for “subsection (b)(5)”. 1988—Subsec. (b)(1). Pub. L. 100–647 substituted “subsection (b)(5)” for “subsection (b)(5) or (d)(4)”. 1986—Subsec. (b). Pub. L. 99–514 struck out former pars. (1) and (3) which related to elections under section 57(c) and 163(d), respectively, and redesignated former pars. (2), (4), and (5), as pars. (1), (2), and (3), respectively. 1980—Subsec. (b). Pub. L. 96–589 inserted reference to section 108(b)(5) and (d)(4). 1977—Subsec. (a)(2). Pub. L. 95–30 struck out subpar. (A) which made reference to the standard deduction provided in section 141, and redesignated subpars. (B) to (G) as (A) to (F), respectively. 1976—Subsec. (a)(2)(G). Pub. L. 94–455, § 2115(c)(2), substituted “wells” for “production subject to the provisions of section 613A(c)”. Subsec. (b). Pub. L. 94–455, § 1901(b)(21)(F), struck out “under section 615 (relating to pre-1970 exploration expenditures),” after “of the United States, and any election”. 1975—Subsec. (a)(2)(G). Pub. L. 94–12 added subpar. (G). 1971—Subsec. (b). Pub. L. 92–178 substituted “,” for “or” after “(relating to pre-1970 exploration expenditures)” and inserted “under section 57(c) (relating to definition of net lease), or under section 163(d) (relating to limitation on interest on investment indebtedness)” after “(relating to deduction and recapture of certain mining exploration expenditures)”. 1969—Subsec. (b). Pub. L. 91–172 substituted “(relating to pre-1970 exploration expenditures) or under section 617 (relating to deduction and recapture of certain mining exploration expenditures)” for “(relating to exploration expenditures) or under section 617 (relating to additional exploration expenditures in the case of domestic mining)”. 1966—Subsec. (b). Pub. L. 89–570 provided for election under section 615 (relating to exploration expenditures) or under section 617 (relating to additional exploration expenditures in the case of domestic mining).

Statutory Notes and Related Subsidiaries

Effective Date

of 1993 AmendmentAmendment by Pub. L. 103–66 applicable to discharges after Dec. 31, 1992, in taxable years ending after such date, see section 13150(d) of Pub. L. 103–66, set out as a note under section 108 of this title.

Effective Date

of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.

Effective Date

of 1986 AmendmentAmendment by section 511(d)(2)(B) of Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, see section 511(e) of Pub. L. 99–514, set out as a note under section 163 of this title. Amendment by section 701(e)(4)(E) of Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, with certain exceptions and qualifications, see section 701(f) of Pub. L. 99–514, set out as an

Effective Date

note under section 55 of this title.

Effective Date

of 1980 AmendmentAmendment by Pub. L. 96–589 applicable to transactions which occur after Dec. 31, 1980, other than transactions which occur in a proceeding in a bankruptcy case or similar judicial proceeding or in a proceeding under Title 11 commencing on or after Dec. 31, 1980, with an exception permitting the debtor to make the amendment applicable to transactions occurring after Sept. 30, 1979; in a specified manner, see section 7(a)(1), (f) of Pub. L. 96–589, set out as a note under section 108 of this title.

Effective Date

of 1977 AmendmentAmendment by Pub. L. 95–30 applicable to taxable years beginning after Dec. 31, 1976, see section 106(a) of Pub. L. 95–30, set out as a note under section 1 of this title.

Effective Date

of 1976 AmendmentAmendment by section 1901(b)(21)(F) of Pub. L. 94–455 effective for taxable years beginning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94–455, set out as a note under section 2 of this title. Amendment by section 2115(c)(2) of Pub. L. 94–455 effective on Jan. 1, 1975 and applicable to taxable years ending after Dec. 31, 1974, see section 2115(f) of Pub. L. 94–455, set out as a note under section 613A of this title.

Effective Date

of 1975 AmendmentAmendment by Pub. L. 94–12 effective Jan. 1, 1975, to apply to taxable years ending after Dec. 31, 1974, see section 501(c) of Pub. L. 94–12, set out as an

Effective Date

note under section 613A of this title.

Effective Date

of 1969 AmendmentAmendment by Pub. L. 91–172 applicable with respect to exploration expenditures paid or incurred after Dec. 31, 1969, see section 504(d)(1) of Pub. L. 91–172, set out as an

Effective Date

note under section 243 of this title.

Effective Date

of 1966 AmendmentAmendment by Pub. L. 89–570 applicable to taxable years ending after Sept. 12, 1966, but only in respect of expenditures paid or incurred after such date, see section 3 of Pub. L. 89–570, set out as an

Effective Date

note under section 617 of this title. Applicability of Certain

Amendments

by Pub. L. 99–514 in Relation to Treaty Obligations of United StatesFor applicability of amendment by section 701(e)(4)(E) of Pub. L. 99–514 notwithstanding any treaty obligation of the United States in effect on Oct. 22, 1986, with provision that for such purposes any amendment by title I of Pub. L. 100–647 be treated as if it had been included in the provision of Pub. L. 99–514 to which such amendment relates, see section 1012(aa)(2), (4) of Pub. L. 100–647, set out as a note under section 861 of this title.

Reference

Citations & Metadata

Citation

26 U.S.C. § 703

Title 26Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73