How do you determine stock attribution held by a limited partnership?

[Guest HelpMeHelpYou]

Beneficiary owns various shares of stock direct and by application of the family attribution rules. Beneficiary is also the general partner of a limited partnership. I don't have the exact details yet on how this is structured, but in general terms, how do you attribute the stock in such a case. Assume I understand that the stock held by a parntership is attributed to the partner proportionately. I just haven't seen any guidance how to answer this question under 318 in the context of a limited partnership. Thanks.

[R. Butler]

Under §1563 a 5% or more partner is treated as owning the partner's proportionate share of the partnership's interests in other organizations.

Under §318 a partner with any onwership interest is treated as owning the partner's proportionate share of the partnership's interests in other organizations.