- 10 -
Accordingly, petitioners determined that Tomson had a $912,000
basis in the property that it sold to Sembler and that the sale
generated a $90,000 capital loss.
I. Shenody, Inc.
In December 1995, Shenody, Inc. (Shenody), was organized as
a Florida corporation. Messrs. Gowni and Mansour owned and
operated Shenody. Shenody leased an Amoco gasoline station
during 1996, 1997, 1998, and 1999.
J. Bishoy, Inc.
In July 1996, Bishoy, Inc. (Bishoy), was organized as a
Florida corporation. Messrs. Gowni and Mansour owned and
operated Bishoy. From the time that Mina of Forest City
transferred the Amoco gasoline station to Bishoy in 1998, Bishoy
operated the station as a Hess gasoline station. Bishoy operated
the gasoline station through 1999.
Bishoy filed Forms 1120S for 1998 and 1999 and reported
ordinary income of $18,580 and $5,295, respectively, from its
operations in those years. On the Schedule M-2 attached to its
Form 1120S filed for 1998, Bishoy’s accumulated adjustments
account was reported to have a balance of $18,580 as of the end
of that year. Bradshaw prepared these Forms 1120S for Bishoy.
K. Ava Anthony, Inc.
In September 1996, Ava Anthony, Inc. (Ava Anthony), was
organized as a Florida corporation. Messrs. Gowni and Mansour
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