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(and to a large extent follows) from the determination that the
corporation is required to make regarding the character and
amount of a corporate distribution or shareholder contribution.
See University Heights v. Commissioner, supra at 281, in which we
held that the Court has jurisdiction over subchapter S items
(including shareholder contributions) that affect shareholder
basis. Because we are not determining the specific amount of an
individual shareholder's basis but are merely deciding the legal
character of constructive corporate distributions and/or
shareholder contributions and whether these items will affect
shareholders' bases in their stock, we have no need to consider
or rely upon "other information" within the meaning of the
regulations.
As a final matter, we observe that our holding on this point
is consonant with the basic policy underlying the unified
subchapter S corporation audit and litigation procedures; namely,
the consistent treatment of subchapter S items among S
corporation shareholders. See S. Rept. 97-640, at 25 (1982),
1982-2 C.B. 718, 729. The failure to resolve the proper basis
treatment of constructive corporate distributions and shareholder
contributions at the corporate level would open the door for
inconsistent treatment of such items at the individual
shareholder level. Accordingly, we shall deny respondent's
motions to dismiss for lack of jurisdiction and to strike insofar
as respondent moves with respect to paragraphs 6(i) of both the
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