- 8 - Cir. 1985); Wilson v. Commissioner, T.C. Memo. 1999-141; sec. 1.704-1(d)(1), Income Tax. Regs. Petitioner has failed to provide any documentation to establish his basis in the respective partnerships. Most of the partnership returns (Forms 1065) have not been filed since the partnerships' inception, nor have the partnerships issued Schedules K-1, Partner's Share of Income, Credits, Deductions, etc., to the partners. The returns that were filed have not been provided to this Court and made part of this record. Petitioner next argues that he is entitled to deduct a loss based on the worthlessness of his partnership interests. In order for petitioner to be entitled to a loss, he needs to establish the worthlessness of his partnership interest and further must substantiate the value of his partnership interests. Even if petitioner’s partnership interests became worthless in 1992, he would not be entitled to a loss deduction because he has not established the value of his partnership interests. As we have previously concluded, petitioner did not present any evidence to establish the amount of his bases in the partnerships. In addition, petitioner did not account for any income, loss, gain, credits, or deductions that are his distributive share as a partner in the partnerships. As petitioner has not established his basis by accounting for his initial and any subsequent contributions to the partnerships, hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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