Estate of Alton Bean - Page 10




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            In the instant cases, the Partnership, not the shareholders of                             
            the S corporation, made the transfer to the Corporation, and only                          
            the Partnership would receive tax bases associated with the                                
            transfer.                                                                                  
                  Despite the similar ownership interests of the partners of                           
            the Partnership and of the shareholders of the Corporation,                                
            petitioners, as shareholders in the Corporation, may not increase                          
            their tax bases in their investments in the Corporation for any                            
            purported value of Partnership assets (in excess of the                                    
            Partnership’s liabilities assumed), for any purported                                      
            Partnership's equity transferred to the Corporation, or for any                            
            amounts owed to the Partnership.                                                           
                  Further, no credible evidence substantiates the existence of                         
            the additional amounts allegedly owed to the Partnership.  We                              
            sustain respondent's deficiency determinations for each year in                            
            issue.                                                                                     
                  Lastly, petitioners contend that the Corporation                                     
            underreported income for the years in issue and that the                                   
            additional unreported income should increase petitioners' tax                              
            bases in the Corporation.  Petitioners, however, for the years in                          
            issue have provided no credible evidence that the Corporation's                            
            income was underreported.                                                                  
                  Under section 6662(a), taxpayers are subject to accuracy-                            
            related penalties on underpayments with respect to which they                              






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