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Petitioner also argues that the only services that he
provided were for Farm & Grove. This argument ignores the fact
that during the years in issue, petitioner was a general partner
at both the 100-lot and the Kiddies 38/91 partnerships. During
the years in issue, the partnerships conducted businesses and
reported distributing profits and losses as well as guaranteed
payments to petitioner. Thus, petitioner is liable for the self-
employment tax.
We hold that petitioner is liable for the self-employment
tax based on moneys that he received from the 100-lot and Kiddies
38/91 partnerships in 1990, 1991, and 1993.46
VII. Issue 7. Flow-Through Adjustment
A. Background
On Schedule K-1 of its 1990 and 1991 Form 1065, the 100-lot
partnership reported petitioner’s share of income as $11,372 in
1990 and a loss of $17,339 in 1991. Petitioner reported the
$11,372 in income from the 100-lot partnership on his amended
1990 Federal income tax return, and he reported the $17,339 loss
on his 1991 Federal income tax return.
B. Discussion
Petitioner argues that the reported income and loss from the
100-lot partnership should be stricken from his 1990 and 1991
46Petitioner is entitled to a deduction in 1990, 1991, and
1993 for paying the self-employment tax. See sec. 164(f).
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