- 20 - III. The Form 4797 Loss A. Introduction Petitioner reported his share of the Form 4797 loss, in the amount of $1,759,987. Principally, the Form 4797 loss resulted from Wedgewood’s disposition of furniture, fixtures, restaurant equipment, a liquor license, and a liquor inventory (the assets). The assets were disposed of pursuant to the deed. At least some of the assets were subject to liens of secured creditors totaling $1,865,000 (the liens). Wedgewood’s adjusted basis in the assets at the time of disposition was $2,506,244. Pursuant to the deed, Wedgewood received nominal consideration of $1, and the disposition was part of a bankruptcylike proceeding carried out under the laws of New Jersey. See N.J. Stat. Ann. secs. 2A:19–1 to 2A:19-50 (West 1987). The disposition was to an assignee for the benefit of Wedgewood’s creditors (the assignee), whose duty it was to liquidate the assets and apply the proceeds to reduce Wedgewood’s indebtedness. See In re: Gen. Assignment for Benefit of Creditors, 169 A.2d 236 (N.J. Super. Ct. 1961). B. Code and Regulations In pertinent part, section 1001(a) provides that the loss from the disposition of property shall be the excess of the 11(...continued) here in question because we believe that the parties are in agreement that we should make an across-the-board decision with respect to the Wedgewood payments.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011