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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, his
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