- 5 - Jerry’s bases in various S corporations. During 1997, the 1995 advances from Perry and Inter-Con were reclassified on Ram’s books (by Ram) first as a note payable to Jerry and then as additional paid-in capital of Jerry. For 1996, Jerry’s distributive share of Ram’s ordinary loss was $805,269, and his basis in Ram was at least $260,000. That minimum basis does not reflect certain other disputed items (1996 disputed items) set forth below: Date Description Amount 1/3/96 TSI check to Inter-Con $28,000 and Inter-Con check to Ram 1/10/96 TSI check to Inter-Con and Inter-Con check to Ram 75,000 3/20/96 Mattel check to Jerry, deposited in Inter-Con account and Inter-Con check to Ram 200,000 4/4/96 TSI check to Ram 100,000 5/17/96 Emerald Carpets1 check to American, endorsed by Ram and deposited in Ram’s bank account 300,000 7/10/96 Mattel check to Inter-Con and Inter-Con check to Ram 200,000 12/18/96 Mattel check to Regions Bank and Regions Bank check to Ram 100,000 1 The check to American from Emerald, a third party corporation unrelated to Jerry, was evidenced by a promissory note from American to Emerald. Ram’s 1996 records reported the $503,000 of these checks written by Inter-Con to Ram as a note payable to Inter-Con. That treatment was reclassified by Ram in 1997 to report the checks first as a note payable to Jerry and then as additional paid-inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011