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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.
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Last modified: May 25, 2011