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9. whether Eric, Brad, and Mark received and failed to
report distributions from an S corporation in excess of their
stock basis;
10. whether Eric, Brad, and Mark are subject to the passive
loss rules with respect to passthrough rental losses from an S
corporation.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulations of facts,
the stipulations of settled issues, and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petitions, each petitioner’s legal residence was Orinda,
California.
1. Background
Burton O. Benson (Burton) served 9 years as an officer in
the U.S. Navy and 23 years as an officer in the U.S. Naval
Reserve, retiring with the rank of Rear Admiral. Burton earned a
B.S. degree in mechanical engineering from the University of
Minnesota. Eric, Mark, and Brad are the sons of the Bensons.6
Glendon M. Benson (Glendon) is the elder brother of Burton.
Esther V. Benson (Esther) was the mother of Burton and Glendon.
6Eric, Mark, and Brad were born on July 24, 1974, Aug. 26,
1976, and Aug. 11, 1981, respectively.
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