- 6 - KCPI. The purchase agreement between Dr. Karason and Dr. Flom did not mention petitioner’s name, indicate that the medical equipment was assigned to petitioner, or that petitioner was going to purchase the equipment. D. Karason Capital Partners Petitioner formed KCP in 1989 with members of his family for the purpose of investing in property.4 Petitioner prepared all of KCP’s Federal partnership tax returns. According to the partnership returns, petitioner was a partner from 1989 through 1993 and 1996 through 2001,5 and Dr. Karason was a partner in KCP from its formation.6 In 2001, petitioner owned a 70-percent interest in KCP, and Dr. Karason owned the remaining 30 percent. During 2001, KCP’s purported business activities included renting real property and breeding race horses. KCP’s Form 1040 Schedule E, Supplemental Income and Loss, for 2001 reported that the rental properties generated a $31,337 loss, and Form 1040 Schedule F, Profit or Loss From Farming, for 2001 reported the horse breeding activities generated a $13,933 loss. KCP’s Schedule K-1, Partner’s Share of Income, Credits, Deductions, 4 The partnership also went by the names Karason Family Partnership and Karason Family Investment Club. 5 Petitioner did not own a direct partnership interest in KCP in 1994 and 1995. 6 From 1990 through 1999, KCP’s partners at various times included petitioner’s mother, father, and various other entities. Petitioner and Dr. Karason were the only partners in 2001.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007