- 19 -
110 T.C. 114 (1998). Thus, petitioners, as S corporation
shareholders, would be precluded from increasing their basis in
the corporate stock on account of COD income excluded from the
corporation's gross income. Cf. Winn v. Commissioner, T.C. Memo.
1998-71.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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