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of a written partnership agreement as evidence that no
partnership was formed. Petitioner correctly states, however,
that the law does not require a written partnership agreement.
See, e.g., Ayrton Metal Co. v. Commissioner, 34 T.C. 464, 472
(1960), affd. in part and revd. in part 299 F.2d 741 (2d Cir.
1962); cf. Commissioner v. Culbertson, supra at 736 (concerning
an oral partnership agreement). Second, respondent contends that
State Savings did not contribute capital or services of
sufficient value to warrant its inclusion in a partnership. We
have concluded, however, that in the unique circumstances of this
case, BCI valued State Savings' provision of credit. Third,
respondent emphasizes the lack of documentary evidence supporting
the existence of a partnership. In light of both parties' rather
casual methods of operation, together with Mr. Barker's attitude
toward applicable regulatory restrictions, the paucity of
documentation in this case is not surprising. Fourth, respondent
contends that no document conferred on State Savings the right to
jointly manage the 70-Acre Tract (and later the remaining 45
acres). State Savings, however, delegated day-to-day management
and development responsibility to BCI and supervised the
venture's progress through Mr. Thomas. Given BCI's expertise in
developing real estate, we do not consider this arrangement
unusual. Fifth, respondent emphasizes that State Savings did not
agree to share in losses. Sharing of losses, however, is not
required. See McDougal v. Commissioner, 62 T.C. 720, 725 (1974).
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