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between a partner's basis and the sum of the partner's
capital account at the end of the year and liabilities as
shown on a Schedule K-1. See generally 1 McKee et al.,
Federal Taxation of Partnerships and Partners, par. 6.05
(3d ed. 1997). However, that general correlation is not
sufficient in these cases to permit us to determine
Mr. Lemons' adjusted basis in the three partnerships at the
end of 1987 and 1988. Accordingly, we sustain respondent's
adjustments with respect to Speed Line Investment, Dondi
Presidents' Partnership II, and 1626 New York Associates,
Ltd. Partnership and reject respondent's adjustments with
respect to the other partnerships.
Worthless Stock Issue
Petitioners claimed losses on Schedules D, Capital
Gains and Losses and Reconciliation of Forms 1099-B, due
to the worthlessness of stock in a Canadian oil company,
Windsor Resources. They claim that Mr. Lemons' basis
in the stock was $8,882.72, and each of them claimed a
deduction in the amount of $4,441.36, one-half of the
alleged basis.
Petitioner testified that he was one of several
persons who borrowed $100,000 to purchase stock in the
company. Petitioner claims that he had a 10-percent
interest in the venture and that he repaid his share
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