Daniel J. Culnen - Page 23

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               D.  Conclusion                                                         
               We find that Wedgewood realized a loss of $515,243 on the              
          disposition of the assets.  Petitioner’s pro rata share of that             
          loss was $376,127 (i.e., 73 percent of $515,243).  We have                  
          already found in section II.E., supra, that petitioner had                  
          sufficient basis to deduct his pro rata share of the Form 4797              
          loss, $376,172.                                                             

                                                  Decisions will be entered           
                                             under Rule 155.                          

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