T.C. Memo. 2005-218
UNITED STATES TAX COURT
MARK O. KAPLAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3624-04. Filed September 20, 2005.
Albert L. Grasso, for petitioner.
Kathleen C. Schlenzig, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: Respondent determined a $123,543
deficiency with respect to petitioner’s 1994 income tax and a
$188,964 deficiency with respect to petitioner’s 1997 income tax.
The deficiencies arise from respondent’s denial of petitioner’s
asserted basis in his wholly owned S corporation, Marc
Construction and Development Co. (Marc), which resulted in
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