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Orad so Orad could open a bank account and that the $1,000
payment she received from Orad was repayment of her 50-percent
share of the Cena contribution. Since the parties agree that
petitioner and Daro were partners in Cena and Cena did contribute
$2,000 to Orad, we find that Orad's payment to Daro was a mere
reimbursement, not a partnership distribution. In addition, we
find that this transaction supports respondent's position that
petitioner and Daro were not co-proprietors of Orad, since Daro
never made a capital contribution to Orad.
Petitioner's own testimony also indicates the lack of a co-
proprietor relationship. Petitioner testified that she
"controlled the Orad account," and that she "got the Orad money."
Based on the foregoing, we find that petitioner has failed
to carry her burden of establishing that Orad was a partnership
for the year at issue. Accordingly, we sustain respondent's
determination.4
Issue 2. Schedule C Deductions
Respondent determined that petitioner was not entitled to
deduct a number of claimed Schedule C expenses. Petitioner
asserts that such expenses are allowable.
4 Although we sustain respondent's determination that Orad was
not a partnership, we find that petitioner had $9,236 of
unreported Schedule C gross receipts from Orad, not $9,710 as
alleged by respondent. The $9,236 represents one half of Orad's
gross receipts ($18,471). Petitioner already included the
remaining $9,235 in her 1985 Federal income tax return.
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