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income tax returns from G & O Associates (G & O) and S-J Mineral
Associates III (S-J III) as follows:
Year Partnership Loss Claimed
1976 S-J III $6,979,298
1976 G & O 2,520,403
1977 S-J III 297,818
1977 G & O 98,298
In addition, respondent determined that S-J III and G & O earned
income in 1977, and that petitioner's distributive shares thereof
were $2,303,276 and $6,978,311, respectively. Petitioner
admitted that the S-J III and G & O partnerships lacked economic
substance and had no business purpose; that the losses he
deducted from them are not allowable; and that his correct
distributive share of ordinary income or loss from S-J III and G
& O for each of the years 1976 and 1977 is zero. We find no
genuine issue of material fact on this issue. We shall grant
respondent's motion for partial summary judgment with respect to
a finding that petitioner is not entitled to certain losses from
the partnerships S-J Minerals Associates III, L.P. and G & O
Associates for 1976 and 1977.
Mining Losses for 1977-81
In the notices of deficiency, respondent disallowed mining
losses claimed by petitioner in the amount of $10 million on each
of his purported Schedules C for the years 1977 and 1978, as well
as his Schedules C for 1979 and 1980. Respondent also disallowed
a mining loss claimed by petitioner in the amount of $100,000 on
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