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 third
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