T.C. Memo. 2005-75 UNITED STATES TAX COURT WILLIAM H. MALOOF, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 15211-02, 17951-03. Filed April 6, 2005. Donald J. O’Connor, for petitioner. Anita A. Gill, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION KROUPA, Judge: Respondent determined deficiencies in petitioner’s Federal income tax by disallowing operating losses sustained by an S corporation in which petitioner was the sole shareholder. After concessions, the sole issue before the Court is whether petitioner is entitled to increase his adjusted basis in the S corporation by $4 million, the amount of a loan a thirdPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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