Timothy L. and Jane Williams - Page 10

                                        - 10 -                                         

          Respondent computed the basis of petitioner’s investment in WIS              
          and the allowable loss for 1991 as follows:                                  


          Contributions or loans, 1990                                                 
                   Personal credit card advances    $19,500                           
                   Proceeds of personal loan         14,000                           
                   Check drawn on own account        15,000                           
                   Own funds                         29,000                           
                    Basis in WIS, 1990                  77,500                         
                    Loss claimed from WIS, 1990         65,169                         
                    Basis in WIS, 1991                  12,331                         
                    Allowable portion of loss                                          
                   claimed from WIS, 1991            12,331                           
                    Basis in WIS, 1992                   - 0 -                         
                    Allowable portion of loss                                          
                   claimed from WIS, 1992             - 0 -                           
               The record does not disclose why, after concluding that                 
          there was “no basis in fact” for claiming a loss that represented            
          a deficit in shareholder’s equity, respondent nevertheless                   
          allowed $12,331 of that loss.  At trial, respondent’s counsel                
          conceded that the pass-through loss from WIS for 1991 was                    
          allowable in excess of $12,331 to the extent that petitioners                
          could document any additional adjusted basis of petitioner’s                 
          investment in WIS.                                                           
               With respect to SPS losses of $40,560 and $36,464 claimed as            
          deductions on petitioners’ returns for 1992 and 1993, respondent             
          determined that $879 was allowable for 1992, and no amount was               
          allowable for 1993.  The notice of deficiency does not identify              
          the source of the $879 of stock or loan basis implied by                     
          respondent’s determination for 1992, and respondent did not offer            
          clarification at any time in these proceedings.  At trial, the               



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