-6- at the shareholder, and not the corporate, level (viz., (1) for 1990 and 1991 the amount of loss, if any, deductible by each LB&M shareholder and (2) for 1990 the amount of capital gain, if any, of each LB&M shareholder). See sec. 6231(a)(5); sec. 301.6231(a)(5)-1T(a), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987). The only matters in dispute in these cases over which the Court has jurisdiction are whether for each of the years at issue LB&M was indebted to each of the selling LB&M shareholders and, if so, the amount of such indebtedness. See University Heights at Hamilton Corp. v. Commissioner, 97 T.C. 278, 281 (1991); sec. 301.6245-1T(a)(1)(v), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003 (Jan. 30, 1987). To reflect the foregoing, An appropriate order will be issued granting respondent's motion.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011