Partial sale of PTP partnership interest

[KarenMM]

My understanding of the passive activity rules is that if you have a partial sale - say 100 shares out of 500 owned - in a year, you are allowed to take carryover passive losses UP TO the amount of ordinary and capital gains that are created from the sale of those partial shares. I am paraphrasing the instructions from form 8582. I also know that there are at-risk rules that come into play here. Is my understanding correct?

[Roland Slugg]

Your understanding is correct. Prior year losses from a PTP can only be deducted in two ways: (1) By future year income and gains, from the same PTP, or (2) by the complete disposition of the T/P's interest in that PTP in a taxable sale.

Current year and prior year suspended losses from a PTP can not be released/used by gains from other passive activities, including other PTPs. The reverse is also true. Income and gains from one PTP can not be used to offset losses from other passive activities, including other PTPs.