Chesapeake Outdoor Enterprises, Inc., Abel Trust, John E. Magee, Jr., Trustee, Tax Matters Person - Page 6

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          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.                                   






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