- 53 -
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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