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from Special Occasions on Schedules E in the amounts of $2,950,5
$5,600, and $2,6896 for the 1991, 1992, and 1993 tax years,
respectively. Special Occasions did not file a U.S. Partnership
Return of Income, Form 1065, for the 1991 tax year.
In a notice of deficiency dated March 14, 1997, respondent
disallowed petitioner's claimed Schedule E losses for the 1991,
1992, and 1993 tax years because petitioner did not provide any
documentation to establish her bases in Special Occasions and
Special O for the years in issue.
OPINION
1. Petitioner's Basis in Special Occasions
As a preliminary matter, this Court notes that the business
accounting books and records purportedly maintained by Special
Occasions and Special O, such as they are, are not reliable.
Furthermore, petitioner's own books and records were poorly
maintained and are incomplete. In response to the disorganized
and sparse records offered by petitioner in this case, respondent
has submitted alternative bases calculations for petitioner's
business interests in both Special Occasions and Special O.
5 Though reported, petitioner concedes that she is not
entitled to claim a nonpassive loss from Special Occasions in the
amount of $2,950 for the 1991 tax year.
6 Though petitioner reported 1993 losses from Special
Occasions in the amount of $2,689 on her Federal income tax
return, the parties stipulated 1993 losses from Special Occasions
in the amount of $2,699.
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