- 10 - 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 theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011