- 40 -
Respondent then reduced this amount by the $1,500 insurance
reimbursement and by $100 in accordance with section 165(h)(1).45
This brings the allowable loss to $20,149 before application of
section 165(h)(2).
Petitioner presented no arguments on brief as to why
respondent’s computation was incorrect. Petitioner’s sole
argument regarding the proper amount of the deduction is
contained in his reply to respondent’s proposed findings of fact,
in which he states: “Parties have agreed that the proper loss
figure is $19,995.” Therefore, respondent’s determination is
sustained.
VI. Issue 6. 1990 Self-Employment Tax
A. Background
Petitioner did not report any self-employment tax due on his
1990 through 1993 Federal individual income tax returns
(including the amended returns for 1990 and 1991).
On the Schedule K-1 attached to the 1990 Form 1065 for the
100-lot partnership and the Kiddies 38/91 partnership, petitioner
was listed as a general partner. Also on the 1990 and 1991
Schedules K-1 for the same partnerships, petitioner reported that
he was entitled to 100 percent of the 100-lot partnership’s gains
or losses and 75 percent of the Kiddies 38/91 partnership’s gains
45Sec. 165(h)(1) provides that theft losses with respect to
personal property must be further reduced by $100.
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