- 4 - In addition to Alviso and GMT, petitioner engaged in the following noncorporate business activities. B. The BAMA Partnership In 1989, petitioner entered into a partnership with Michael D. Mitchem named BAMA Equipment (BAMA). BAMA was engaged in the business of selling new and used trucks. Petitioner owned a 50- percent interest in BAMA. During the years in issue, BAMA wrote numerous checks to petitioner and/or his related corporation(s), which he deposited into noncorporate bank accounts over which he had signatory authority. BAMA paid petitioner rent for the use of one of his real properties, which he deposited into the aforesaid bank accounts. BAMA was also a sponsor of petitioner’s racing business.3 On his 1991 and 1992 returns, petitioner claimed deductions for passthrough losses from BAMA of $56,786 and $8,777, respectively. For those years, petitioner’s capital accounts in BAMA were negative $26,046 and $34,823, respectively. As previously stated, respondent concedes loss deductionss for 1991 and 1992 of $26,046 and $8,777, respectively. Additionally, respondent concedes petitioner’s capital loss deduction of $3,000 for 1992. BAMA dissolved in 1992. 3Petitioner’s racing business is discussed in detail below.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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