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only that he “would say United Way got some” and that he also
made contributions to his church. He could not recall the exact
amounts of such contributions. In the absence of any written
records or other substantiation for the charitable contributions,
we uphold respondent’s disallowance of the deductions therefor.
The next item at issue is petitioner’s entitlement to
certain limited liability company (LLC) losses. Petitioner
claimed partnership losses of $21,600 and $20,763 in 1996 and
1997, respectively, for an LLC. Respondent disallowed these
losses in full.
An LLC with more than one member is treated as a partnership
for Federal income tax purposes unless the LLC elects otherwise.
See sec. 301.7701-3, Proced. & Admin. Tax Regs.
The LLC in which petitioner was a member did not file a
partnership return in either year. In 1996, petitioner filed a
Schedule E, Supplemental Income and Loss, reflecting a
partnership loss. In 1997, petitioner completed a Schedule C,
Profit or Loss From Business, and then claimed approximately 56
percent of the net loss reported on this form as his distributive
share of the LLC’s loss. Petitioner presented no evidence to
support the claimed losses or the underlying expenses listed on
the Schedule E or C. Furthermore, at least a portion of the
expenses listed on the schedules, if actually incurred, were not
related to any business. For example, legal and professional
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