- 10 - Respondent emphasized the fact that certain partnership formalities, including a written partnership agreement, were not present in this case. We do not find the absence of such formalities to be fatal to the existence of a partnership. As the Supreme Court stated in Commissioner v. Culbertson, supra at 744-745: If, upon a consideration of all the facts, it is found that the partners joined together in good faith to conduct a business, having agreed that the services or capital to be contributed presently by each is of such value to the partnership that the contributor should participate in the distribution of profits, that is sufficient. * * * See also Estate of Winkler v. Commissioner, supra. Respondent argues that even if the rental real estate activities constitute a partnership for Federal income tax purposes, the record does not contain sufficient evidence to support a determination of petitioner's basis in his partnership interest at the end of 1992. We disagree. The amount paid for the Oak Street properties is in the record. Furthermore, the Pughs, petitioner's partners, were able to prepare their 1992 Federal income tax return reporting income and expenses from the Oak Street properties. Petitioner asserts that in addition to all stipulated expenses and adjustments, he is entitled to deduct 50 percent of the partnership expenses incurred during 1992 in the following amounts:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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