(d) The requirement is to determine the item that is
deductible in the computation of the ordinary income of a partnership.
Guaranteed payments to partners are always deductible
in computing a partnership’s ordinary income. Contributions to
recognized charities and short-term capital losses cannot be deducted
in computing a partnership’s ordinary income because
they are subject to special limitations and must be separately
passed through so that any applicable limitations can be applied
at the partner level. Similarly, dividends are an item of portfolio
income and must be separately passed through to partners in
order to retain its character as portfolio income when reported
on partners’ returns.