T.C. Memo. 2001-61 UNITED STATES TAX COURT FREDERICK H. JACKSON III AND PAMELA S. JACKSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11045-98. Filed March 13, 2001. R denied P deductions for his pro rata share of the losses of an S corporation on the grounds that P had insufficient adjusted basis in his S corporation shares. See sec. 1366(d)(1), I.R.C. P argues that the corporation lacked borrowing power and his guaranty of loans to the S corporation should be deemed to signify his borrowing of the loan proceeds and subsequent contribution of those proceeds to the capital of the S corporation, which would increase his adjusted basis sufficiently for him to deduct the losses in question. Held: P has failed to prove that the indebtedness in question was not indebtedness of the S corporation; therefore, P has failed to prove that he had sufficient adjusted basis to deduct the S corporation losses in question.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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