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to the guarantors as the primary obligors on the loans. We find
that the loans were to the corporation.
D. Conclusion
Petitioner did not, on account of the loans, make a capital
contribution to the corporation. Therefore, petitioner has
failed to prove that his basis in the shares exceeded zero.
V. Conclusion
For the years in issue, petitioner may not deduct his pro
rata share of the losses of the corporation. Therefore, except
as explained supra note 1, we sustain respondent’s determination
of deficiencies.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011