Woody F. Lemons - Page 31

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                  During the audit of petitioners' 1987 and 1988                      
             returns, respondent's revenue agent noted that petitioner's              
             ending capital, as shown on the Schedules K-1 issued by the              
             partnerships, consisted of negative amounts.  Respondent's               
             revenue agent asked petitioners' representatives why                     
             petitioners had deducted losses in excess of their basis in              
             each of the partnerships.  Petitioners' representatives                  
             stated that their practice was to deduct the amount of                   
             any loss shown on a Schedule K-1, irrespective of the                    
             taxpayer's basis in the partnership.  Respondent's agent                 
             also asked petitioners' representatives to substantiate the              
             amount of any liabilities that would increase petitioner's               
             basis in any of the partnerships.  Petitioners did not                   
             provide any substantiation to respondent's agent.                        

             Worthless Stock Issue                                                    
                  On the Schedules D, Capital Gains and Losses, filed                 
             with their 1986 tax returns, both petitioners reported a                 
             long-term capital loss in the amount of $4,441.35 that is                
             labeled "Windsor Resources".  Respondent disallowed these                
             losses in the notices of deficiency.                                     

             Self-Employment Tax                                                      
                  For 1987, each petitioner filed a Schedule SE,                      
             Computation of Social Security Self-Employment Tax, with                 






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