Carl E. Jones and Elaine Y. Jones - Page 33

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            (c) of section 1368 for distributions of property to the                                  
            shareholder shall be applied by taking into account the                                   
            adjustments to the basis of the shareholder's stock described in                          
            section 1367.  Thus, the adjustments to the shareholder's basis                           
            in his stock for the losses and deductions of the S corporation                           
            must be made before the adjustments required for distributions.                           
                  If a shareholder's basis in his stock is reduced to zero by                         
            the shareholder's pro rata share of the S corporation's losses                            
            and deductions, section 1367(b)(2) requires that the amount of                            
            the losses and deductions that exceed the shareholder's basis in                          
            his stock be applied to reduce (but not below zero) the                                   
            shareholder's basis in any indebtedness of the S corporation to                           
            the shareholder.  Sec. 1367(b)(2)(A).                                                     
                  The aggregate amount of the losses and deductions taken into                        
            account in determining the tax of a shareholder for any taxable                           
            year, however, shall not exceed the sum of the adjusted basis of                          
            the shareholder's stock in the S corporation and the adjusted                             
            basis of any indebtedness of the S corporation to the                                     
            shareholder.  Sec. 1366(d)(1).                                                            
                  Thus, petitioner's basis in his Development stock would be                          
            reduced first for the losses and deductions (but not below zero),                         
            and if the losses and deductions exceeded his stock basis, the                            
            excess would then reduce petitioner's basis in Development's                              
            indebtedness to him (but not below zero).  The adjustments to                             






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