Woody F. Lemons - Page 53

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                                        1987                  1988                    
                                                                                     
                                        Loss     Loss     Loss     Loss               
                                        Deducted  Disallowed     DeductedDisallowed         
             Speed Line Investment      ($2,091.48) ($2,091.48) ($2,035.02)($2,035.02)        
             Oakbrook III               (7,050.85)  (7,050.85) (12,453.97)(12,453.97)        
             Dondi Presidents' Partnership II(24,273.40) (24,273.40)      422.35(1,431.00)         
             1626 NY Associates Ltd.                                                  
             Partnership                (6,035.00)(6,035.00)  (4,931.60)(4,931.60)         
             Bear Creek West Rental Prop.(10,102.50) (10,102.50)       ----                 
             Haywood Lane Joint Venture (9,082.00)  (9,082.00)       ----                 
             Murfreesboro Road Joint Venture (32,104.53)      --       --      --     
             Lemons & Hite              (751.37)      --  (646.29)      --            
             Dondi Motor Car Properties (2,166.00)      --(2,283.98)      --          
             Berkley Apartments. Ltd. Partnerships(4,067.51)      --(640.68)      --            
             Caprice Investments        (271.51)      --  594.00      --              
             Freeport-McMoran Energy Partners, Ltd.     206.50--       6.50      --                
             Freeport-McMoran Resource Partners, Ltd.      --      --       --      --
                                        ___________ ___________ ___________ ___________
                                        (97,789.65) (58,635.23) (21,968.69)(20,851.59)        

                  The subject notices of deficiency disallowed the                    
             partnership losses claimed by each petitioner on the ground              
             that the amount deducted was "more than you have 'at                     
             risk'".  In her post-trial brief, respondent asserts that                
             the subject partnership losses should be disallowed for two              
             reasons.  First, as to three of the partnerships, Speed                  
             Line Investment, Dondi Presidents' Partnership II, and 1626              
             New York Associates Ltd. Partnership, respondent asserts                 
             that the losses should be disallowed "because petitioner                 
             has not shown that his adjusted basis in any of these                    
             partnerships exceeded his distributive share of the                      
             partnership losses under �704(d)."  In effect, respondent                
             contends that petitioner had "insufficient basis"                        
             to support the deduction of the subject partnership losses.              
             Second, as to all of the partnerships for which an                       







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