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Cadillac. We conclude that petitioner has substantiated that he
paid $63.59 in sales tax on a motor vehicle in 1986 and is
entitled to a deduction in this amount.
E. Partnership Losses
During 1985, 1986, and 1987, petitioner was a 25-percent
partner in a real estate partnership called Horizon Partners.
Petitioner, on his 1985, 1986, and 1987 tax returns, claimed loss
deductions from Horizon Partners in the amounts of $5,191.33,
$4,171.25, and $3,876.25, respectively. Respondent argues that
petitioner has not established his adjusted basis in Horizon
Partners during the years in issue and therefore is not entitled
to deduct any partnership losses. Petitioner argues that he has
established his basis in Horizon Partners.
Section 704(d) allows a partner's distributive share of
partnership loss as a deduction only to the extent of the
adjusted basis in his partnership interest at the end of the
partnership year in which the loss is incurred. Petitioner
testified that in 1983 he invested $6,600 in Horizon Partners.
There is, however, no evidence of the amount of his adjusted
basis during the years in issue or of the adjustments he made to
his basis in previous years. Petitioner did not demonstrate that
he is entitled to deduct his proportionate share of partnership
losses from Horizon Partners in 1985, 1986, or 1987. We
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