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G�nther’s behalf after May 31, 1992, we sustain respondent's
determination regarding petitioner’s FYE May 31, 1993, worthless
stock deduction.
III. Conclusion
Because petitioner’s shares of G�nther’s stock became
worthless during FYE May 31, 1992, petitioner is entitled to
deduct a worthless stock loss of $13,938,562 for that year but is
not entitled to any of the bad debt deductions claimed.
Consistent with respondent’s concession and this opinion,
additional amounts charged to the intercompany account after May
31, 1992, excluding only the bank debt assumed during FYE 1994,
shall be taken into account in computing petitioner’s capital
loss from the sale of G�nther in FYE May 31, 1994.
We have considered all arguments for a result contrary to
that expressed herein, and, to the extent not discussed above, we
conclude that those arguments are irrelevant, moot, or meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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