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beginning of the year and adding partnership income received
during the year. Respondent's computation represents a
concession of sorts, because it produces the largest possible
basis to which petitioner may be entitled, since it does not
account for any distributions that may have occurred during the
year. We will accept respondent's computation of basis in this
case. Petitioner's challenges are unavailing, and petitioner has
offered no other evidence from which we might compute basis.
Thus, we accept respondent's approach, and petitioner's basis in
each of the partnership interests is set out in the following
table:
Basis (Beginning Cap.
Name Acct. + Income)
Dime Box No. II $1,056.32
Dime Box No. III (Petitioner) 3,730.90
Dime Box No. III (M & A) 873.26
CAG Farmout 2,797.60
66 Farmout (Petitioner) 873.68
66 Farmout (M & A) 581.79
Further, in some cases only portions of petitioner's interests
were actually pledged as collateral and foreclosed on, so that
petitioner's loss deduction is limited to the following amounts:6
6 Respondent uses the Schedules K-1 stipulated into evidence
to compute basis, and petitioner agrees as to the accuracy of the
Schedules K-1. However, in three instances the Schedules K-1
fail to reflect the effect of the foreclosures upon petitioner's
ownership of certain partnership interests; namely, the 66
Farmout interest held in petitioner's name, the 66 Farmout
(continued...)
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