- 5 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011