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Petitioner argues that he is entitled to deduct an $86,889
loss from Only Kids and that the 1998 Form 1120S, a single bank
statement, and his testimony establish his basis in Only Kids.
We disagree with petitioner when he asserts that he has
established that he has a basis in Only Kids. The Form 1120S
does not contain sufficient information for us to establish that
he has any basis in Only Kids. Fehlhaber v. Commissioner,
94 T.C. 863, 869 (1990), affd. 954 F.2d 653 (11th Cir. 1992).
Nor does the bank statement, which simply lists Only Kids’
deposits and other credits for April 1998, establish that
petitioner had any such basis. Although petitioner observes
correctly that the statement reports that funds of $105,000 were
wired into Only Kids’ bank account during April 1988, the
statement does not indicate the source of those wire transfers.
In that petitioner testified vaguely and incoherently that the
deposits were from his personal account, and that the record does
not otherwise support that testimony, we decline to find the
subject matter of that testimony as a fact. We conclude that
petitioner’s adjusted basis in Only Kids was zero for 1998 and,
hence, that he was not entitled to deduct the referenced loss.3
3 We are mindful that petitioner, as the only shareholder of
Only Kids, obviously had to have at least once invested in the
corporation and that Only Kids’ 1998 Form 1120S reported that
Only Kids’ balance sheet as of December 31, 1998, listed capital
stock and additional paid-in-capital of $425,000 and $2,049,649,
respectively. In that the record contains no credible evidence
(continued...)
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