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Touch’s failure to produce invoices, receipts, checks, or other
business records during the audit or at trial.
We sustain respondent’s determinations disallowing
petitioner’s deductions for professional fees, marketing
expenses, and amortization.
IV. Other Issues
Petitioner raised, and the parties briefed, two additional
issues: (1) Whether In Touch’s members had sufficient bases to
deduct their distributive share of In Touch’s 2000 net loss and
(2) whether property in the form of promissory notes contributed
to In Touch was “at risk” under section 465(a). Neither party
disputed that these issues involved partnership items that we
could properly decide in this partnership-level proceeding.
We decline to decide the remaining issues identified in this
opinion for several reasons. The first is that respondent
determined in the FPAA that the bases of In Touch’s members and
their at-risk amounts as of December 31, 2000, were limited to
$50,000, the amount of capital contributed as of December 31,
2000. Because we have sustained respondent’s determination
disallowing the vast majority of In Touch’s deductions for 2000,
it no longer appears to be necessary for us to decide whether the
members had sufficient bases or at-risk amounts to claim their
distributive shares of In Touch’s adjusted net loss.
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