Woody F. Lemons - Page 60

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             "other" liabilities was $27,934.  For 1988, petitioners                  
             reported income from the Dondi Presidents' Partnership II.               
                  Petitioner was a limited partner in the 1626 New York               
             Associates Ltd. Partnership.  Petitioner testified that he               
             paid approximately $405,000 for his interest in the                      
             partnership by making a cash downpayment and signing a                   
             promissory note.  Petitioner could not recall the amount                 
             of the downpayment or promissory note.  According to                     
             petitioner, his obligation under the note was "bonded" by                
             Continental Casualty in Chicago, which ultimately obtained               
             a judgment of $246,000 against him.  Petitioners did not                 
             introduce the judgment into evidence, and the record does                
             not state the date of the judgment.                                      
                  We note that the Schedules K-1 issued to petitioner by              
             the 1626 New York Associates Ltd. Partnership show that his              
             capital at the end of 1987 and 1988 was ($112,988.56) and                
             ($157,628.56), respectively.  We further note that the                   
             Schedule K-1 for 1988 shows nonrecourse liabilities of                   
             $309,682 and other liabilities of $57,352, and the Schedule              
             K-1 for 1987 shows nonrecourse liabilities of $428,488 and               
             other liabilities of $53,057.                                            
                  Petitioners make a general argument that respondent                 
             erred by disallowing losses from the subject three                       
             partnerships because the Schedules K-1, issued by the                    






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