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rental losses (viz., a claimed rental loss of $7,627 with respect
to property located on Hilton Head Island and a claimed rental
loss of $22,383 with respect to a property identified as “Evian”)
and windfall profit tax withheld in 1982 of $720.
Schedule E had the following notation with respect to the
claimed partnership losses of $189,965: “SEE STATEMENT 2".
Statement 2 showed, inter alia, the following partnerships and
the following claimed loss of each such partnership that gave
rise to the total claimed partnership losses of $189,965 shown in
Schedule E:
Name of Partnership Partnership Loss
Kelly-Brock Drilling Partners 1981-11 $64,753
Odessey Partners 81 Limited Partnership1 57,087
Matagorda Limited Partnership II1 10,036
Madison Recycling 58,089
1Petitioner and Mr. Korchak also claimed losses with respect
to Mr. Korchak’s three oil and gas partnerships for their taxable
year 1981.
There was nothing about the claimed $58,089 Madison Recycling
loss that would have made that claimed loss stand out in rela-
tionship to the other partnership losses claimed in the 1982
joint tax return.
Statement 2 also showed for each of the partnerships identi-
fied below the following amount as “PROPERTY QUALIFIED FOR
INVESTMENT CREDIT NEW RECOVERY PROPERTY - OTHER”:
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