Andrew and Margita Zards et al. - Page 3

                                        - 3 -                                         
               The common denominator in these consolidated cases is the              
          claim of tax losses arising from an investment in Good Shepherd             
          Home, Inc. (Good Shepherd), an S corporation within the meaning             
          of section 1361.  We must determine whether such losses are                 
          allowable, and, if not, whether petitioners are liable for the              
          additions to tax determined by respondent.2                                 
                                  FINDINGS OF FACT                                    
          Introduction                                                                
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts filed by the parties and the                       
          accompanying exhibits are incorporated herein by this reference.            
          Petitioners Andrew and Margita Zards are individuals who made a             
          joint return of income for 1986 and who resided in Lisle,                   
          Illinois, at the time their petition was filed.  Petitioner                 
          Andrew Zards became a shareholder of Good Shepherd on March 17,             
          1986.  Petitioners Janet Weinman and Vincent Donahue are                    
          individuals who resided in New York, New York, at the time their            
          petitions were filed.  Petitioners Weinman and Donahue both                 


          2    We need determine no deficiency for petitioners Vipulis for            
          1985.  Their losses from Good Shepherd Home, Inc., for that year            
          were subchapter S items, within the meaning of sec. 6245.  The              
          tax treatment of those items is determined at the corporate                 
          level.  See sec. 6242.  The proper treatment of those items was             
          the subject of a proceeding before this Court:  Good Shepherd               
          Home, Inc., Valdis Vipulis, Tax Matters Person v. Commissioner,             
          docket No. 28415-89.  Our decision in that case resulted in the             
          disallowance of substantially all of the losses from Good                   
          Shepherd Home, Inc., claimed by petitioners Vipulis for 1985.  We           
          must still, however, decide the additions to tax.                           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011