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on January 5, 1999, and also allowed for the recognition of
$300,000 of the pro rata share of the company’s losses.
With respect to the 2000 tax year, petitioners contend that
the $1,100,000 basis of each advance offset the $800,000
repayments on January 3, 2000, and also permitted each petitioner
to recognize $300,000 of the pro rata share of the company’s
losses.
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