T.C. Memo. 1998-104
UNITED STATES TAX COURT
ABDUL HAFIZ AND RAWNAQ A. HAFIZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15079-96. Filed March 16, 1998.
Lawrence H. Richards, for petitioners.
Katherine Lee Wambsgans, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioners' income taxes of $52,837 and $73,542 for the taxable
years 1989 and 1990, respectively. The sole issue remaining for
our consideration is whether petitioners, as S corporation
shareholders, may increase their bases in the S corporation by
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