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distributions and/or shareholder contributions in this context
constitute subchapter S items pursuant to section 301.6245-
1T(a)(5), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003
(Jan. 30, 1987).
On the other hand, the parties disagree whether the above-
quoted regulations expand the scope of the term "subchapter S
item" to encompass the determinations regarding shareholder basis
that petitioners seek to place in dispute in these cases.
Petitioners contend that, inasmuch as constructive corporate
distributions and/or shareholder contributions are considered
subchapter S items, the Court's jurisdiction encompasses the
legal question whether such constructive corporate distributions
and/or shareholder contributions will result in adjustments to
the shareholders' bases in their stockholdings. Petitioners rely
on the flush language of section 301.6245-1T(c)(2), Temporary
Proced. & Admin. Regs., 52 Fed. Reg. 3004 (Jan. 30, 1987), and
Dakotah Hills Offices Ltd. Partnership v. Commissioner, T.C.
Memo. 1996-35, in support of their position. Respondent counters
that the Court's holding in Dial, Inc. v. Commissioner, 95 T.C. 1
(1990), is controlling, and that the matters relating to
shareholder basis that petitioners are attempting to place in
dispute do not constitute subchapter S items.
Our review of the allegations in the petitions that
respondent finds objectionable reveals that petitioners in fact
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