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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-in
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Last modified: May 25, 2011