-4-
FSAA. Paragraph 5 of the amended petitions in these cases
alleges in pertinent part:
Petitioner * * * disputes the determination of the
Commissioner regarding the basis of the individual
shareholders in the stock of Petitioner. The dispute
here does not arise from the adjustments to income and
expenses at the corporate level. The dispute arises in
the computation of the basis of the individual share-
holders in their stock. This computation of basis at
the shareholder level in turn determines the amount and
timing of the loss amounts deductible to the sharehold-
ers.
* * * * * * *
The Commissioner erred in failing to include in the basis
computation the amount of money loaned to Petitioner by
certain individual shareholders of Petitioner during calen-
dar year 1990.
* * * * * * *
The basis computation used by Commissioner at the share-
holder level does not include an increase to basis as a
result of these loans.
The amended petition in docket No. 1609-96 relating to 1990 also
alleges:
All of the * * * adjustments except * * * Shareholders
[sic] Capital Gain on Cash Distributions in Excess of
Basis, (in the amount of $87,935) are agreed.
(b) Petitioner disputes the said amount [relating to
the shareholders' capital gain] * * *. * * *
On June 20, 1997, the Court permitted Mr. Alvarado (current
tax matters person) to replace Mr. Doerfel as the tax matters
person in these cases.
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