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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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