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Issue 12. Whether Kanter had Unreported Partnership Income for
1978
OPINION
In the notice of deficiency for 1978, respondent determined
that the Kanters failed to report partnership income (loss) in
the net amount of $4,953 from the following sources:
T.C. Family Trust ($512)
Everglades Trust No. 1 1,093
Everglades Trust No. 2 1,093
Everglades Trust No. 3 1,093
Everglades Trust No. 4 1,093
Everglades Trust No. 5 1,093
Total 4,953
Kanter did not introduce any evidence on this issue.
Therefore, respondent's determination is sustained.
Issue 13. Whether the Kanters Are Entitled to a Loss From GLS
Associates for 1981
OPINION
On their Federal income tax return for 1981, the Kanters
claimed a loss of $4,283 on Schedule E relating to an entity
referred to as GLS Associates. Respondent disallowed the claimed
loss because the Kanters did not prove that GLS Associates was
engaged in an activity entered into for profit and that
deductible expenses were incurred by it in excess of income. The
Kanters introduced no evidence on the issue. Therefore,
respondent's determination is sustained.
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