- 14 - and Dr. Karason were brothers. The Court finds this difficult to believe. Petitioner was employed by the IRS for more than 17 years either auditing or supervising the audits of taxpayers. He should have known to document the purported purchase of the medical equipment, the lease agreement with KCPI, and the medical equipment’s cost and FMV. Petitioner did not produce any documentation showing either he invested in or purchased the medical equipment. For the foregoing reasons, the Court concludes petitioner is not entitled to deduct the costs of the medical equipment under sections 179 and 167.11 II. Karason Capital Partners Petitioner contends he had a sufficient basis in KCP to allow him to deduct $31,689 as passthrough losses from KCP in 2001. Respondent contends petitioner failed to substantiate his purported adjusted basis in KCP, and he cannot deduct the $31,689 of passthrough losses from KCP. Section 704(d) limits the deduction of a partner’s distributive share of partnership loss to the partner’s adjusted basis in the partnership at the end of the partnership year. Sec. 1.704-1(d)(1), Income Tax Regs. The partner’s adjusted 11 Because this Court found that petitioner did not invest in or purchase the equipment, Dr. Karason’s bank loan payments of $16,662 did not constitute income to petitioner.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007