8 he maintained for his coventurers, and he also admitted that he took some of such funds for his personal uses. He totally failed to show the extent, if any, where respondent was in error as to her determination of additional unreported income. (2) As to the additional unreported capital gains for 1987, respondent admitted that some cost basis had been allocated to petitioner in her computation of the capital gains. There is no evidence in this record, and petitioner has produced none, that petitioners had any cost basis in excess of that allowed by respondent which would reduce the net capital gains in any of the recomputations that respondent made. Sec. 1012. In fact, to the extent that any of the testimony at trial herein or any of the exhibits admitted into evidence touched upon it at all, it was strongly suggested that petitioner had no cost basis in the various ventures in any amount. (3) As to the additional capital losses claimed by petitioners as an offset, and more, to the capital gains determined by respondent, petitioner has produced no evidence of any amounts of loss, but instead has relied on a general argument that the judgments rendered against him, as well as the abandonment of various projects by the joint ventures, produced capital losses which he could deduct. Quite aside from petitioner's failure to prove any cost basis in any of these ventures, as we have mentioned above, it does not appear that any of the judgments which petitioner admits were rendered againstPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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