- 31 - 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, withPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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