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addition to tax under section 6651(a)(1) for 1992 in the amount
of $9.
The issues are: (1) Whether petitioners had sufficient
bases in the stock and indebtedness of Electronic Business
Systems (EBS), a subchapter S corporation, to claim loss
carryovers from the corporation in the years in issue; (2)
whether this Court has jurisdiction to review respondent's
application of claimed overpayments for 1991 and 1992; and (3)
whether petitioners are liable for the accuracy-related penalties
and the addition to tax.
The facts may be summarized as follows. Petitioners resided
in Fort Wayne, Indiana, at the time the petition was filed.
EBS Losses
Prior to the years at issue, Thomas E. Hogan III
(petitioner) was employed by EBS. Petitioner owned 33.33 percent
of the stock in EBS for which he had paid approximately $3,500.
In June of 1990, EBS filed for chapter 11 bankruptcy. EBS ceased
business activities during 1990.
For 1990, EBS reported a loss of which petitioner's aliquot
share reported on a Schedule K-1 was $18,222. On their 1990
joint Federal income tax return petitioners claimed $3,989 of the
$18,222 loss. EBS had incurred losses in years prior to 1990.
While petitioners have claimed aliquot shares of those losses in
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