- 4 - under section 7491(a). Barela v. Commissioner, T.C. Memo. 2004- 175. An S corporation’s loss flows through to its shareholders on a pro rata basis. Sec. 1366(a). Section 6037(c) requires consistent treatment between the S corporation and shareholder’s returns. It follows that adjustment to an S corporation’s loss requires the adjustment to a shareholder’s pro rata share of that loss. Any remedy that petitioner may have against the water company lies in State court, rather than with this Court. On this record, we conclude that petitioner’s reported pro rata share of the water company’s loss should be reduced by the amount determined by respondent. Accordingly, we sustain respondent’s determination. Contentions we have not addressed are irrelevant, moot, or without merit. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011