T.C. Memo. 2002-64 UNITED STATES TAX COURT BARRY GUSTIN AND CAROLINA GUSTIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5192-01. Filed March 7, 2002. R disallowed certain losses claimed by Ps from various partnerships in tax years 1997, 1998, and 1999. R determined that P-H’s basis in each of the partnerships was limited to P-H’s cash contributions, which did not include P-H’s contributions of subscription notes. R applied sec. 704(d), I.R.C., and disallowed losses which exceeded P-H’s adjusted bases in the partnerships. The partnerships involved are subject to the unified partnership procedures contained in secs. 6221- 6234, I.R.C. R has begun a partnership-level examination of two partnerships for which Ps claimed losses in 1998 and 1999. However, R did not initiate a partnership-level examination of the partnership for which Ps claimed a loss in 1997. The normal period of limitations for making partnership-level adjustments regarding 1997 expired, and R agrees that he is bound by the partnership’s treatment of partnership items.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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