- 42 -
determined by inspection of other parts of the partnership
information return, Form 1065. This may be illustrated in the
instant cases by comparing lines 1 through 11 of the stipulated
1985 Pacific partnership information return with the parties’
stipulation as to Pacific’s gross income.
Table 1
Pacific’s Partnership
Information Return Pacific’s Stipulated
(Form 1065, 1st. page)1 Gross Income2
4. Ordinary income (loss) -7,705Rental income (gross) $13,708
from other partnerships Rental income (gross) 11,730
and fiduciaries See STMT#2 Rental income (gross) 17,048
Rental income (gross) 9,024
6a. Gross rents $63,723 -275,383Rental income (gross) 12,213
6b. Minus rental expenses Total rental income 63,723
$ STMT ATTACHED Form 4797, line 19 703,950
6c. Rental income (loss) Form 4797, line 1d 246,000
Total 1,013,673
9. Net gain (loss)(Form 4797, 34,935
line 17)
11. TOTAL income (loss) -248,153
(combine lines 3 through 10)
1 Lines 1,2,3,5,7,8, and 10 do not have any entries.
2 The stipulation specifically excludes any gross income
from Pacific’s 2d-tier partnership.
As is apparent, more than 90 percent of Pacific’s stipulated
gross income shown on its partnership information return is
related to line 9, and not lines 1 through 7. Further, line 9
does not tell the whole story--it shows only $34,935 net income
from Form 4797, but the parties’ stipulation shows a total of
$949,950 gross income from Form 4797. Thus, contrary to the
implications of respondent’s contentions, respondent’s actions in
the stipulations show that it is necessary to examine more than
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