- 2 -
Thomas and Janice Gleason, pro sese.
John W. Stevens, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined the following
deficiencies and penalties with respect to petitioners’ Federal
income taxes:
Penalty
Year Deficiency Sec. 6662, I.R.C.
1994 $18,583 $3,717
1995 663,679 132,736
After concessions, the principal issues for decision are:
(1) Whether petitioners’ income for 1995 and 1996 should be
increased on account of (a) their pro rata share of ordinary
income from various S corporations and/or (b) property
distributions from certain of the S corporations.
(2) Whether losses claimed by petitioners with respect to
their interests in two of the S corporations, Alofs Manufacturing
Co. (Alofs) and Target Components, Inc. (Target), should be
adjusted for the years 1994 and 1995. Subsumed in this question
is the proper computation of petitioners’ bases in their Alofs
and Target stock.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011