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cumulative losses from WRI.6 WRI reported a loss of $784,160 for
its fiscal year 1988. Respondent determined that WRI's 1988 loss
was $598,873, and that the Wises and Eicher could each carry
forward $299,437 of that loss.
As of July 31, 1987, Wise and Eicher claimed a basis in WRI
of $2,236,140 and $2,813,047, respectively, which they calculated
as follows:
Claimed Basis in WRI as of 7/31/87
Eicher Wise
Capital stock $ 750 $ 750
Guarantee of the HMC loan 1,250,000 1,250,000
Loan backs of payments on 567,130 340,277
the Hersco mortgage
1987 interest on the 5,308 3,185
Hersco mortgage
1986 Intent advances to WRI 505,635 229,834
Wesco's loans to WRI 588,413 392,276
as of 7/31/87
Loan backs to WRI 204,675 522,484
Total basis before losses $3,121,911 $2,738,806
as of 7/31/87
WRI losses claimed (840,617) (840,617)
as of 7/31/87
Unexplained basis 531,753 337,951
Total basis claimed $2,813,047 $2,236,140
as of 7/31/87
Respondent determined that the Wises and Eicher had the
following basis as of July 31, 1987:
6In the notice of deficiency, respondent determined that
Wise's and Eicher's share of WRI's cumulative losses was $848,424
on July 31, 1987.
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