Woody F. Lemons - Page 59

                                       - 59 -                                         
             1987 and 1988, and do not contain any entry on the lines                 
             provided for "partner's share of liabilities".  Petitioner               
             testified that his share of partnership liability exceeded               
             the negative balance of his capital account by more than                 
             the amount of the loss deducted for 1987 and 1988.                       
             However, the record contains no documentary evidence to                  
             substantiate that testimony.                                             
                  Petitioner was a general partner in the Dondi                       
             Presidents' Partnership II, a partnership formed to acquire              
             and eventually resell 10 condominium units in Oceanside,                 
             California.  He held a 10-percent interest in the                        
             partnership in 1987 and 1988.  He claims that, in addition               
             to other debts of the partnership for which he had no                    
             liability, the partnership borrowed $350,000 from Paris                  
             Savings in Paris, Texas, and he "had full liability" for                 
             that debt.  Petitioner also testified that Paris Savings                 
             eventually obtained a judgment against him with respect to               
             that debt in the amount of $306,690.87.  Petitioners did                 
             not introduce the judgment into evidence, and the record                 
             does not state the date of that judgment.  We note that the              
             Schedule K-1 issued to petitioner by Dondi Presidents'                   
             Partnership II for 1987 shows that petitioner's share of                 
             "nonrecourse" liabilities was $65,700 and his share of                   








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