13 owned C or S corporation to a wholly owned S corporation does not increase the shareholder's basis in the S corporation. Meissner v. Commissioner, T.C. Memo. 1995-191; Burnstein v. Commissioner, T.C. Memo. 1984-74. Respondent argues that petitioner has not proven the amount of his basis in Bob Wade Ford. We agree in part and disagree in part. We find that petitioner invested $125,000 in Bob Wade Ford in 1988 and $275,000 in 1989. Petitioner produced canceled checks showing his contributions to the dealership in 1988 and 1989 and records of his Merrill Lynch money market account that showed petitioner's contributions to Bob Wade Ford for 1988. Petitioners reported gains from sales of Bohannon, S.A. stock on their 1988 and 1989 returns exceeding the amount they invested in Bob Wade Ford in those years. However, petitioner did not prove that he had a basis in Bob Wade Ford at the end of 1987. Petitioner testified that he has contributed his own funds to the dealership each year since 1970, except in 1990. He testified that he kept annual summaries of his contributions and gave them to Kane. Kane testified that petitioner's basis in Bob Wade Ford was $1,079,854 in 1988 and $1,272,953 in 1989. Kane and Dan Gallogly, a certified public accountant, both testified that they calculated petitioner's basis in Bob Wade Ford. Petitioner produced canceled checks and records of his Merrill Lynch money market account showing that he made some contributions to the dealership before 1988. ThesePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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