Program Operations Manual System (POMS)
RS 01802.306 Earnings from Partnerships — Operating Policy
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a.
The partnership must be carrying on a trade or business in order that a partner's
share of earnings be considered NESE.
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b.
The earnings must not be excluded as rent, dividends, etc.
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c.
The individual members of the partnership are considered to be self-employed, and
are credited with their distributive share of ordinary partnership income, whether
or not actually distributed. See RS 01802.360 and RS 01802.375.