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$12,768 and $19,073, and for the Franklin Green partnership of
$3,596 and $4,140. In an amended return, he claimed an
additional 1979 partnership loss of $23,709. The only evidence
relied upon to support the Bowling Green and Franklin Green
claimed losses are the partnership agreements, testimony that
petitioner was a partner, testimony that he made unidentified
amounts of capital contributions, the partnership tax returns,
and tax trial balance workpapers. Reliance on partnership
returns to establish basis in a partnership or to establish a
loss generally is insufficient to prove the claimed losses.
Patterson v. Commissioner, T.C. Memo. 1984-58.
In addition, the claimed losses were disallowed in the
notice of deficiency on the ground that petitioner had not met
the at-risk rules of section 465. The 1979 Bowling Green
partnership return reflects over $448,000 of debt as nonrecourse.
No contrary showing has been made by petitioner.
Finally, the only evidence for the additional 1979 loss
claimed on the amended return is the return itself and the return
preparer's vague statement, which petitioner mischaracterizes.
Contrary to petitioner's assertion that Mr. Dutton calculated
basis and other items, Mr. Dutton had no recollection as to what
the loss was attributable to. The tax returns are insufficient
to prove the underlying claimed loss. The disallowance of the
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