- 7 - believes he is entitled to a $60,000 loss deduction.3 All of the properties with respect to which petitioner sustained losses were partnership interests. In general, the adjusted basis of a partner's interest in a partnership equals the amount of money and the adjusted basis of property contributed by the partner to the partnership, increased by the partner's distributive share of partnership income and certain other amounts, and decreased by distributions and the sum of the partner's distributive share of partnership losses and certain other expenditures. Sec. 705(a). Petitioner's contentions notwithstanding, there is no provision in the Code allowing a partner a stepped-up basis in his partnership interest as a result of its being pledged as collateral. Thus, we reject petitioner's argument that the basis of each partnership interest was equal to its fair market value.4 Petitioner next argues, in the alternative, that respondent's computation of basis is wrong in any event. First, petitioner argues that respondent improperly relied on the Schedules K-1 in computing basis. Second, petitioner argues that respondent double counted IDC in making that computation. 3 At trial, petitioner also argued that he was entitled to a loss deduction of $40,000 -- the difference between the $100,000 loan secured by the Dime Box No. II, Dime Box No. III, and CAG Farmout partnership interests and the $60,000 fair market value of those interests at foreclosure. On brief, petitioner merely maintains that the loss is equal to $60,000. 4 For the same reason, we reject petitioner's argument at trial, identified supra note 3, that his loss was equal to $40,000.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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