- 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 NextLast modified: November 10, 2007