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the shareholders did in fact use petitioner to such an extent
that its separate identity must be recognized.
We sustain respondent's determination in the notice of
deficiency that the sale of the property, in 1993, resulted in a
taxable gain to petitioner in the amount of $112,053 and that
petitioner is entitled to a net operating loss carryover from
1992 in the amount of $9,290. To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011