- 6 - of Income, Credits, Deductions, Etc., and Schedules K-1, Shareholder's Share of Income, Credits, Deductions, Etc., attached to its return for the year in issue. On July 15, 1996, respondent issued an FSAA with respect to Chesapeake's TYE March 19, 1992. Respondent disallowed deductions for accrued interest expenses in the amount of $317,583 forgiven by Chase Manhattan and Tec Media in the same year as the accrual. Furthermore, under the heading "Other Adjustment: Basis of Shareholders", respondent determined an adjustment to the shareholders' aggregate basis in Chesapeake stock in the amount of $995,000. In "Remarks" included on the Schedule of Adjustments, respondent stated that The discharge of indebtedness income that is excluded from gross income under section 108(a) * * * does not pass through to the Subchapter S Corporation's shareholders as a separately stated item of tax-exempt income under section 1366(a)(1). Accordingly, the shareholders' stock basis under Section 1367 is not increased. Petitioner timely filed a petition for readjustment of subchapter S items on October 9, 1996. Pursuant to a Stipulation of Agreed Adjustments filed on September 29, 1997, petitioner conceded the correctness of respondent's adjustment relating to the disallowed deductions for accrued interest expenses. On brief, respondent conceded that the proposed adjustment to Chesapeake's shareholders' stock basis was inappropriate at the corporate level.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011