Atlas Partnerships...anyone have clients that own them?

[AZ-Tax]

Please refer to the post regarding

NY Partnership K-1

and

Partnership follow up questions

all by AZ - Tax

[JoshinNC]

You've got me working on Sunday now AZ

Please refer to the post regarding

NY Partnership K-1

and

Partnership follow up questions

all by AZ - Tax

I'm trolling the web looking for anything I can find. I did find a link to a company that sells these things and their site says

"A general partner's share of net income or loss constitutes earnings from self-employment. It is likely there will be a loss in the year the well is drilled (due to IDC). This loss may be used to offset self-employment income. Generally, after a general partner converts to a limited partner, income from the partnership is not subject to self-employment tax. Because the partnership carries no debt, a general partner's conversion to limited partner status should not result in adverse tax consequences. IRC Section 1402, Rev. Rul. 84-52, 1984 -1 C.B. 157. "

My client has no "SE income" because he is a W-2 wage earner. I don't think this can be used to offset W-2 income (but now I'm scared I may be wrong).

Here's the link:

http://www.mwfin.net/information/TaxBenefits.asp

I sure hope someone will post a response that backs up our opinions (or refutes them and provides some good reasons).

[JoshinNC]

Found something

Here's a link to Atlas' "tax guide" for 2007 investments:

https://k1.atlasamerica.com/(S(koow443jgj0vod2ac4fsyyq5))/images/2007%20K-1%20Instructions%20(Final).pdf

It looks as though they concur with our contention that the Box 14, Code A number is only used in determining SE tax for self-employed investors. The important numbers are the Box 1 income and the depletion info.