- 17 - explanation as to why the expenses should have been recorded by Silver Glen, if they were paid by petitioner personally on behalf of Marc. We conclude and hold that petitioner has failed to prove that he is entitled to any basis in Marc with respect to the alleged legal expense. VI. Conclusion Petitioner has failed to establish that as of December 31, 1997, he had adjusted basis in Marc greater than the $321,859 that respondent has conceded. Accordingly, pursuant to section 1366(d), petitioner’s 1997 loss deductions from Marc are limited to $321,859. To reflect respondent’s concession, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011