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longer held any partnership interest in Russell Street. As
reported by Russell Street on the 1987 partnership Schedules K-1,
Mr. Bach received a general and limited partner's allocable share
of net long-term capital gain of $42,156 and $1,756,
respectively, and deductions related to partnership portfolio
income of $4,990 and $208, respectively. As a result of these
distributive shares of income and deduction, Mr. Bach's general
partner capital account deficit was reduced to $14,183 and his
limited partner capital account deficit was reduced to $6,822.
Petitioners did not report any gain in relation to the disposal
of Mr. Bach's interest in Russell Street on their 1987 Federal
income tax return.
On that return, petitioners claimed on Schedule D, Capital
Gains and Losses and Reconciliation of Forms 1099-B, long-term
capital loss carryovers from 1985 and 1986 from partnerships, S
corporations, and fiduciaries in the amount of $175,107.81.
Petitioners provided no substantiation to support these claimed
losses. During 1987, petitioners had a number of other
transactions, which were not reported on Schedule D, including:
$1,889 received from the sale of petitioners' shares in the
Neuberger & Berman Government Money Fund; $1,889 received from
the sale of petitioners' shares in the Guardian Mutual Fund;
$1,780 received from the sale of petitioners' shares in the
Manhattan Fund, Inc.; and $2,864 from the sale of petitioners'
shares in the USAA Cornerstone Fund.
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