T.C. Memo. 1999-38
UNITED STATES TAX COURT
JAMES H. PUGH, JR., AND ALEXIS C. PUGH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27237-96. Filed February 8, 1999.
Charles H. Egerton and Jane D. Callahan, for petitioners.
Judith C. Winkler, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: Respondent determined deficiencies in
petitioners' Federal income tax of $83,181 and $76,723 and
penalties under section 6662(c) of $16,636 and $15,432 for the
taxable years 1990 and 1991, respectively. After concessions,
the issues for decision are:
(1) Whether petitioner James H. Pugh, Jr. (petitioner), may
increase his basis in stock of an S corporation by the amount of
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