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accounts in the partnerships during the year in issue as
reflected on the Schedules K-1:
DB III DB III
Name 66 (Pet.)66 (M & A)DB II (Pet.) (M&A) CAG
Cap. acct. ($761.00)($508.00)$373.00 $3,051.00$763.00 $2,109.00
beginning 1987
Ord. income $1,634.68$1,089.79$683.32 $679.90 $110.26 $688.60
Distributions ($1,539.09)($1,026.03)($1,056.32)($3,891.52)($169.04)($2,383.06)
Cap. acct. ending($665.41)($444.24)0.00 ($160.62)$704.22 $414.54
1987
% Cap. ownership3% 2% 4% 4% 1% 2%
beginning 1987
% Cap. ownership13% 12% 0% .25% 11% .5%
ending 1987
1 The Schedules K-1 are inconsistent with the findings as to the amount pledged as collateral and foreclosed
on, as shown in the previous table. See infra note 6.
For each partnership interest, the beginning capital account
balance reflects the intangible drilling costs (IDC) incurred and
deducted by the partnership.
OPINION
Amount of Loss
We must first decide the amount of the loss that petitioner
incurred as a result of the foreclosure of his partnership
interests.2 In the notice of deficiency, respondent took the
2 Respondent concedes that petitioner had a loss equal to
his basis rather than a gain, even though respondent also
concedes that the fair market value of petitioner's interests in
Dime Box No. II, Dime Box No. III, and CAG Farmout exceeded his
bases in those interests. Cf. Correra v. Commissioner, T.C.
Memo. 1997-356. The finding of fact as to the fair market value
of petitioner's foreclosed interests in the Dime Box No. II, Dime
Box No. III, and CAG Farmout partnerships, collectively, is based
(continued...)
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