Timothy L. and Jane Williams - Page 22

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          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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