Albert J. and Helen R. Desantis - Page 42

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          of loans from petitioner to the partnerships; (2) loans from the            
          partnerships to petitioner; or (3) nontaxable partnership                   
          withdrawals.  Since petitioner is advancing the same theories of            
          nonincludability as he did with respect to payments he received             
          from the partnerships, we see no need to reiterate our analysis             
          herein.  We hold that petitioner failed to report income from               
          Newtowne and related transactions in the total amounts as                   
          follows:                                                                    
                                        1982                                          
               Amount received                              $162,000.00               
               Ford van                                        7,800.00               
               Saltergate I                                  120,000.00               
          289,800.00                                                                  
               Less amount reported                         (126,986.00)              
               Less respondent's concession                   (4,000.00)              
               Total                                      158,814.00                  
                                        1983                                          
               Amount received                            $1,422,500.00               
               Cost savings                                  106,037.66               
          1,528,537.66                                                                
               Less respondent's concession                 (150,000.00)              
               Total                                     1,378,537.66                 
                                        1984                                          
               Cost savings                                 $174,028.76               
               Park Place                                    180,000.00               
               Owner's check request                          28,000.00               
               Riat's architectural services                  30,000.00               
          Less amount reported with respect                                           
          to Park Place                               (30,525.00)                     
          Less respondent's concession                   (1,371.02)                   

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