“ If a go-by means of entity doesn't furnish the information that an API proprietor (i.e., the individual that finally pays the tax) wants to find out the Section 1061 recharacterization amount (e.g., gadgets required to compute the One 12 months Gain Quantity and Three 12 months Acquire Quantity) and the proprietor can't in any other case substantiate these amounts, the quantity reclassified as short-term capital beneficial properties under Section 1061 should be calculated with out lowering the One Year Gain Quantity by capital acquire objects not topic to Part 1061 (e.g., Part 1231 gain, qualified dividends) or positive aspects from capital pursuits, and the Three 12 months Acquire Quantity shall be calculated as if the entire taxpayer’s share of partnership long-term capital gain gadgets are held for less than three years. ”