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As to the adjustments made by respondent with respect
to each of the subject three partnerships, Speed Line
Investment, Dondi Presidents' Partnership II, and 1626 New
York Associates, Ltd. Partnership, the issue is whether
petitioner's distributive share of partnership loss exceeds
the adjusted basis of his interest in the partnership at
the end of the partnership year in which the loss occurred,
such that respondent could correctly disallow the loss
pursuant to the limitation imposed by section 704(d).
Petitioners bear the burden of proving that respondent's
adjustment is incorrect and, in that connection, they
must prove Mr. Lemons' adjusted basis in each of the
three partnerships at the end of 1987 and 1988. Pucci
v. Commissioner, T.C. Memo. 1984-672.
Petitioners have failed to meet their burden of proof.
They did not prove Mr. Lemons' adjusted basis in any of the
three partnerships at the end of 1987 or 1988. They rely
on Mr. Lemons' testimony which, in the case of each of the
three partnerships, consists of a description of the
partnership and a general statement that he was liable for
partnership obligations that are not reflected on the
Schedules K-1 issued by the partnership. At no time does
Mr. Lemons state the amount of his basis in any of the
partnerships. We agree that there may be a correlation
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