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 against
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