- 22 -
Taxable Year 1991
Adjustments Attributable to WIS
Investment basis 32,846
WIS income per return 1,541
WIS “other losses” per return 136,748
WIS nonseparately computed loss
(as conceded by respondent) 135,207
Pass-through loss allowable 32,846
Pass-through loss suspended 102,361
Investment basis after pass-through adjustment - 0 -
- - - - - -
Loss allowable 32,846
Loss allowed per notice of deficiency 12,331
Reduction in taxable income 20,515
Taxable Year 1992
1. Adjustments Attributable to WIS
Investment basis - 0 -
WIS income per return 6,777
WIS gain on distribution 25,647
WIS suspended loss treated as incurred in 1992 102,361
WIS nonseparately computed loss 69,937
Pass-through loss allowable - 0 -
Pass-through loss suspended 69,937
Investment basis after pass-through adjustment - 0 -
Petitioner’s gain on excess distribution 30,647
2. Adjustments Attributable to SPS
Investment basis 31,526
Allocable share of SPS loss per return 40,560
Allocable share of SPS nonseparately
computed loss (as conceded by respondent) 40,560
Pass-through loss allowable (as conceded by
respondent) 31,526
Pass-through loss suspended 9,034
Investment basis after pass-through adjustment - 0 -
- - - - - -
Net loss allowable (31,526- 30,647) 879
Loss allowed per notice of deficiency 879
Additional loss allowable - 0 -
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