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 inPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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