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(B) the basis to the distributee, as
determined under section 732, of any unreal-
ized receivables (as defined in section
751(c)) and inventory (as defined in section
751(d)).
On the record before us, we find that petitioners have
failed to carry their burden of establishing (1) Mr. Ramsburg’s
adjusted basis in his interest in Kildare Timmy27 and (2) the
fair market value of each of the noncash assets (i.e., the racing
and breeding horses and the stud rights) that Kildare Timmy
distributed to Mr. Ramsburg in liquidation of his interest in
that partnership. On that record, we further find that petition-
ers have failed to carry their burden of showing whether the
total of (1) the Kildare Timmy bank account balance of $908.71
and (2) the aggregate of the respective fair market values of the
racing and breeding horses and the stud rights that we have found
Kildare Timmy distributed to Mr. Ramsburg in liquidation of his
interest in that partnership was equal to, greater than, or less
than Mr. Ramsburg’s adjusted basis in such partnership interest.
As a result, we find that petitioners have failed to carry their
burden of showing (1) whether Mr. Ramsburg realized a gain or a
loss upon Kildare Timmy’s distribution to him of the horses, stud
rights, and bank account balance in question and (2) whether all
27Respondent appears to take the position, with no explana-
tion, that Mr. Ramsburg’s adjusted basis in his interest in
Kildare Timmy was $139,569 (before taking into account Kildare
Timmy’s $4,592 loss from trade or business activities that it
claimed in its 1998 partnership return and that it reported in
that return as Mr. Ramsburg’s distributive share of such loss).
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