- 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 anPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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