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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