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.
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