- 10 -
California on September 9, 2003. That petition was denied on
October 22, 2003. No other actions concerning the validity of
the buyout were pending on the date of trial.
E. Petitioner’s Basis in Green Hills Stock, Distributive Share
of Income From Green Hills, and Income Tax Returns for 2000
and 2001
Petitioner’s basis in Green Hills stock was $8,315,584 on
December 31, 1999. Green Hills reported $4,275,909 as
petitioner’s distributive share of income through October 13,
2000.4
Petitioner filed Federal income tax returns for 2000 and
2001 on the cash receipts and disbursements method of accounting.
On his 2000 return, petitioner did not include a distributive
share of income from Green Hills. Petitioner did not include in
income on his 2000 and 2001 returns the $41,585,388 payment or
any of the interest credited to the account in which he had
deposited that payment.
4 In the notice of deficiency, respondent determined that
petitioner’s basis in Green Hills was $12,523,085 for purposes of
determining petitioner’s gain on the sale of Green Hills stock on
Oct. 13, 2000. Adding a $4,275,909 distributive share of income
to petitioner’s basis in Green Hills of $8,315,584 on Dec. 31,
1999, does not produce the basis determined by respondent. The
record does not show whether respondent determined petitioner’s
basis correctly. Thus, if we decide that the $41,585,388 is
includable in petitioner’s income in the year received, the
parties shall compute the amount of gain under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011