Wayne M. and Janet L. Johnson - Page 8

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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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