- 20 - 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. WePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011