Daniel J. Culnen - Page 1
















                                 T.C. Memo. 2000-139                                  


                               UNITED STATES TAX COURT                                


                           DANIEL J. CULNEN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 25551-92, 6496-94.         Filed April 13, 2000.           


                    The issues for decision are:  (1) whether P had                   
               sufficient basis with respect to an S corporation                      
               to permit him to deduct his pro rata share of                          
               that corporation’s ordinary losses for the years in                    
               question; and (2) whether (A) the corporation suffered                 
               a sec. 1231, I.R.C., loss from the disposition of                      
               property in one of those years and (B) P had sufficient                
               basis to permit him to deduct his pro rata share of                    
               that loss.                                                             
                    1.  Held:  P established that he had sufficient                   
               basis for all years;                                                   
                    2.  Held, further, P established that the                         
               S corporation suffered only a portion of the sec. 1231,                
               I.R.C., loss claimed; held, further, P had sufficient                  
               basis to deduct his portion of the loss suffered.                      










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