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$70,000 to reflect that they were personally liable on loan
92107. Petitioner shareholders urge us to conclude that they
made an economic outlay simply by signing the loan documents.
Respondent contends that the loan was not made until 1995;
therefore, the issue of whether the loan requires an adjustment
to the bases of Christopher and Gregory in 1994 is not before us.
Respondent further contends that Deborah did not make an economic
outlay with respect to loan 92107.
Loan 92107 was not made until 1995. Since the loan did not
exist in 1994, it cannot have any bearing on the calculation of
Christopher’s or Gregory’s basis in Cox Tomato during 1994.10
Deborah is also not entitled to any adjustment in her basis
by reason of loan 92107. Although Deborah signed as a borrower
on the promissory note memorializing the loan, Deborah did not
make any payments to the Oklahoma Bank on loan 92107, nor did she
transfer any cash or property to Cox Tomato in connection with
loan 92107. We hold, therefore, that Deborah has failed to prove
that she made any economic outlay with respect to loan 92107 and,
absent such proof, she is not entitled to increase her basis in
Cox Tomato by reason of the loan.
10Christopher asserts that he is entitled to increase his
basis in Cox Tomato to reflect the $70,000 loan (the 92107
loan) and an additional $66,000 loan that he obtained in 1995.
We decline to decide whether these loans increase Christopher’s
basis, since Christopher has not filed a petition with respect to
any year after 1994.
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