T.C. Memo. 1999-287 UNITED STATES TAX COURT ROBERT W. EBERLE AND DEBORAH M. EBERLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10218-98. Filed August 30, 1999. James M. Kamman, for petitioners. Jeffrey A. Schlei and Michael H. Salama, for respondent. MEMORANDUM OPINION FOLEY, Judge: By notice dated March 30, 1998, respondent determined deficiencies in, and penalties relating to, petitioners' 1993, 1994, and 1995 Federal income taxes. After concessions, the sole issue for decision is whether discharge of indebtedness income that is excluded, pursuant to section 108, from the gross income of an S corporation increases the basis ofPage: 1 2 3 Next
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