- 151 - Petitioner also claimed losses of $3,596 for 1979 and $4,140 for 1980 from the Franklin Green partnership. However, there are no invoices, canceled checks, or other primary records of the Franklin Green partnership in evidence for 1979 and 1980. Hence, it cannot be established that Franklin Green partnership paid expenses that were ordinary and necessary expenses resulting in distributive partnership losses. Therefore, petitioner is not entitled to the claimed losses from Franklin Green partnership in computing 1979 and 1980 taxable income. Similarly, petitioner claimed losses from the McZand Corporation, a subchapter S corporation, of $11,997 for 1979 and $39,147 for 1980. He became the sole shareholder of McZand Corporation in 1979. No canceled checks, invoices, or other primary records of McZand Corporation for 1979 and 1980 are of record for these claimed losses. The McZand Corporation's return for 1979 reported an $85,317 gain from the sale of Westgrove real estate to petitioner as sole shareholder. However, McZand Corporation did not include that amount in calculating its income. In March 1980 petitioner transferred 100 percent of his ownership in McZand Corporation to Caspian Florida, a subsidiary of CDC. Petitioner is not entitled to McZand Corporation losses of $11,997 and $39,147 in computing 1979 and 1980 income.Page: Previous 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 Next
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