Linda Klyce - Page 9




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          61(a)(13), 702(a)(8).  With respect to an S corporation, a                  
          shareholder shall take into account his or her pro rata share of            
          the corporation's losses and deductions to the extent that the              
          total losses and deductions do not exceed the sum of the adjusted           
          basis of the shareholder's stock and the shareholder's adjusted             
          basis of any indebtedness of the S corporation to the                       
          shareholder.  See sec. 1366(d)(1).                                          
               The first issue is whether petitioner is entitled to net               
          operating loss carryforwards from her 1985, 1986, and 1987 tax              
          years to her 1988, 1989, and 1990 tax years.  Petitioner reported           
          negative taxable income amounts of $9,771 and $17,928 on her                
          Federal income tax returns for 1985 and 1986, respectively.  On             
          her 1986 return, petitioner claimed a $9,771 net operating loss             
          carryover from 1985.  On her 1987 return, petitioner reported               
          adjusted gross income of $3,269 and zero taxable income.  On                
          September 12, 1989, petitioner filed an amended return for 1987             
          claiming a $27,699 net operating loss carryover from 1986, plus a           
          $14,750 loss from an unidentified partnership, for a total loss             
          of $39,180.4                                                                



          4                                                                           
               The $27,699 loss carried over from 1986 to 1987 results from           
          the $9,771 loss reported for 1985 plus the $17,928 loss reported            
          for 1986.  The $39,180 total loss claimed for 1987 results from             
          the $27,699 loss carried over from 1986 plus the $14,750                    
          unidentified partnership loss reported for 1987, minus the $3,269           
          adjusted gross income previously reported for 1987.                         




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