independently recognizable entity apart from its partners, and
that business conducted by a partnership is considered apart from
any business activity conducted by its partners on their own
633 F.2d 512, 517 (7th Cir. 1980) (expenses were characterized as
“pre-operational costs” of the partnership even though the
general partner was already in the same business), affg. 72 T.C.
521 (1979); Brannen v. Commissioner, 78 T.C. 471, 505 (1982)
(“the partnership is an independently recognizable entity apart
from its partners for the purposes of the calculation of its
taxable income under section 703”), affd. 722 F.2d 695 (11th Cir.
1984); see also Polakof v. Commissioner, 820 F.2d 321, 323 (9th
Cir. 1987) (in characterizing partnership income “it is the
dominant economic motive of the partnership, not that of the
individual investors, that is determinative”), affg. T.C. Memo.
1985-197; Tallal v. Commissioner, 778 F.2d 275, 276 (5th Cir.
1985) (“When the taxpayer is a member of a partnership, we have
interpreted 26 U.S.C. § 702(b) to require that business purpose
must be assessed at the partnership level.”), affg. T.C. Memo.
The frequency of the taxpayer’s sales “is highly probative
in the real estate context because the presence of frequent sales