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Furthermore, if petitioner paid the annual dues with funds
obtained from the joint venture, as mentioned above, there is
no evidence in the record of petitioner's indebtedness to
the joint venture for such payment. Therefore, based upon
the record of these cases, we cannot find that petitioner
"paid" annual dues of $10,500 to the beach club in 1986 as
required by section 162(a). Accordingly, we hereby sustain
respondent's disallowance of the deductions that petitioners
claimed in the amount of one-half of such amount, $5,250.
Partnership Losses for 1987 and 1988
The partnership losses that each petitioner claimed as
deductions on a Schedule E for 1987 and 1988 and the amount
that respondent disallowed according to respondent's post-
trial brief, are as follows:
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