Given that a gain in one PTP can't be used to offset a loss in another PTP (e.g., USAC income offsetting a SUN loss), failing to split the PTPs will open you to that problem, and the record keeping to ensure you don't violate the rule.
In addition, if ET ever divests one of those positions, the disposition can only free up suspended losses from the divested PTP. So this is another record keeping problem that splitting the K-1's solves.
On sale, Ordinary Gain will be split between the different entities, so that's no problem. The basis adjustment only needs to be done once (for the top level Cap Gain calculation), so also no issue.
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**Note also, I'm not a Tax Preparer/CPA. Just a volunteer, seasoned, TurboTax user.
Use any advice accordingly!
