Stephen H. Glassley and Judith Glassley, et al. - Page 28

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               b.  Petitioner Paul S. Mahoney                                         
               Dr. Mahoney resided in Los Angeles, California, at the time            
          he filed his petition in the instant cases.  During 1981, he                
          worked as a physician.  Dr. Mahoney reported adjusted gross                 
          income of $175,155 on his 1981 Federal income tax return.                   
               On December 11, 1981, Dr. Mahoney subscribed to one                    
          partnership unit in JDP for a price of $50,000.  As a result of             
          his capital contribution to JDP, Dr. Mahoney acquired an 11.1-              
          percent capital interest in JDP.  Also on December 11, 1981, he             
          executed the signature page to the certificate and agreement of             
          limited partnership and certificate of fictitious name, offeree             
          questionnaire, and a promissory note in the amount of $35,000               
          payable to JDP in installments of $15,000 on or before May 1,               
          1982, $10,000 on or before May 1, 1983, and $10,000 on or before            
          May 1, 1984, together with interest of 10 percent per year of the           
          unpaid balance.  Dr. Mahoney paid to JDP or its escrow agent                
          $15,000 on December 15, 1981, $16,160 on April 18, 1982, $12,000            
          on April 18, 1983, and $11,000 on May 1, 1984.                              
               On his 1981 Federal income tax return, Dr. Mahoney claimed a           
          net loss relating to JDP of $40,529.  By notice of deficiency               
          dated June 21, 1989, respondent disallowed the partnership loss             
          relating to JDP that Dr. Mahoney had claimed for 1981 on the                
          grounds that he had not established:                                        
               any amount was paid pursuant to a research and                         
               development agreement or, if paid, that such                           
               expenditures were not preconceived shams lacking                       
               economic substance.                                                    



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