Islame Hosny has published his article, Tax Treatment of Short Sale Contributions to Partnerships, in Tax Notes. The Abstract is as follows:
The application of section 704(c) to contributions of short sales to a partnership is not specifically addressed in section 704(c) or the regulations thereunder. This article relies on well-established principles from other sections of the code and regulations, case law, revenue rulings, legislative history, and other authorities to synthesize an approach for analyzing the tax treatment of such contributions in a manner that is consistent with the purpose of section 704(c) as well as the congressional intent behind subchapter K.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.