Section 1.707 of the Department of the Treasury Regulation

Title 26 - Internal Revenue

Chapter I - Internal Revenue Service, Department of the Treasury

Sub Title A - Income Tax

Part 1 - Income Taxes

Normal Taxes and Surtaxes

Partners and Partnerships

Determination of Tax Liability

Section 1.707 - Partners, not partnership, subject to tax

Partners are liable for income tax only in their separate capacities.  Partnerships as such are not subject to the income tax imposed by Subtitle A but are required to make returns of income under the provisions of section 6031 and the regulations thereunder.  For definition of the terms "partner" and "partnership", see sections 761 and 7701(a)(2), and the regulations thereunder.  For provisions relating to the election of certain partnerships to be taxed as domestic corporations, see section 1361 and the regulations thereunder