T.C. Memo. 2000-30
UNITED STATES TAX COURT
ROBERT H. AND MILDRED M. BETTISWORTH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12447-98. Filed January 21, 2000.
Richard W. Hompesch II, for petitioners.
Stephen P. Baker, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: Respondent determined a $45,715 deficiency in
petitioners’ 1994 Federal income tax. The deficiency primarily
stems from the disallowance of a net operating loss carryover due
to insufficient basis in petitioners’ S corporation stock.
The underlying issue for decision is whether discharge of
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