- 10 - 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 professionalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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