Lillie M. Tripp - Page 6




                                       - 5 -                                          
        partnership expense (i.e., $24,052 as a salary expense in 2003),              
        respondent no longer contests the amount of losses reported by the            
        Tripp partnership for any of the years in issue.  However,                    
        respondent posits that petitioner is not entitled to deduct her               
        distributive share of those losses, maintaining that she lacks a              
        sufficient basis in the partnership to do so.                                 
             As stated above, respondent contests a $24,052 salary expense            
        that the Tripp partnership deducted in 2003.  That expense                    
        represents the value of property (cash and used beauty salon                  
        equipment) transferred to a cosmetologist who had rendered                    
        services to the Tripp partnership.  Respondent does not dispute               
        that cash and equipment were transferred to the cosmetologist in              
        exchange for services rendered to the Tripp partnership but rather            
        contests the value claimed for the property transferred.                      
        Moreover, respondent contends that Mr. Tripp, rather than the                 
        Tripp partnership, was the owner of the property before the                   
        transfer.                                                                     
                                    Discussion                                        
             Rule 142(a)(1) provides that the burden of proof is on                   
        respondent with respect to any new matter.  Respondent concedes               
        that the issue as to whether petitioner had a sufficient basis in             
        her interest in the Tripp partnership to use the partnership                  


             4(...continued)                                                          
          ceased operating, because of storage expenses for its equipment.            






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next 

Last modified: November 10, 2007