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Neither the note nor the mortgage limited the purchasers'
individual liability to Citytrust.
At the time of the purchase, petitioner and the three other
purchasers intended to sell the property as soon as possible.
Because of a change in economic conditions, the property could
not be sold. As a result, the property continued to be rented to
tenants through 1990. In February 1987, a checking account was
opened in the name of BASS and was thereafter used to deposit
rental income and pay expenses related to the property. BASS is
an acronym using the first letters of the last names of Messrs.
Baker, Allingham, Raymond Staron, and Bernard Staron.
Gross income and deductions related to the property for 1987
were reported on a U.S. Partnership Return of Income (Form 1065).
This partnership return was filed using the name "Bass
Associates, George D. Allingham Gen Ptr".1 Bass Associates' 1987
partnership return reported gross income of $47,329, total
expenses of $144,988, and a net loss of $97,659.
On Schedules K-l, Partner's Share of Income, Credits,
Deductions, etc., attached to the 1987 partnership return, the
partners' percentages of profit, loss, and ownership were
reported as follows:
1Bass Associates had acquired an employer identification
number that it used on its partnership returns for the years 1987
through 1990.
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