Curtis R. and Lynn Bitker - Page 35

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               On the basis of the Bitker partnership’s  assets  and                  
          liabilities as of the beginning and end of each year at issue as            
          agreed to by respondent, its income as adjusted during the                  
          examination of the partnership return, and the cash distributions           
          to petitioners of $634,830 for 1996 and $458,488 for 1997, which            
          necessarily included the deemed distribution for payment of                 
          petitioners’ personal expenses, we conclude that the distributions          
          did not exceed petitioners’ bases in their partnership interests.           
          The computations we have used in reaching this conclusion  are as           
          follows:                                                                    

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