- 20 - The parties stipulated that petitioners alleged a $7,842,696 basis in Alofs, calculated as follows: $50,000 Cash contribution with initial ownership of 20% 6,000,000 Loan from taxpayer through Comerica bank 500,000 Loan from selling shareholders backed by CD from taxpayer 196,000 Sales price reduction of Excellence 696,696 Portion of the sales proceeds from Excellence 400,000 Loan from Excellence to Alofs Respondent disallowed most of these amounts and determined a basis in Alofs of $877,574, comprising the $50,000 contribution, $356,760 in sales proceeds from Excellence, and the $470,814 shown on the Schedule K-1 from Alofs for FYE 1995. The parties likewise stipulated that petitioners alleged on audit a basis in Target of $2,138,304, which amount included the initial investment of $35,000 and $2,103,304 in sales proceeds from Excellence. Respondent, in contrast, computed a basis in Target of $584,133: $35,000 Initial investment 1,070,279 Portion of sales proceeds from Excellence (616,947) Loss for FYE 1995 (70,163) Property distribution for FYE 1994 113,311 Income for FYE 1993 (42,242) Loss for FYE 1992 101,485 Income for FYE 1991 5,675 Income for FYE 19905 (12,265) Loss for FYE 1989 Incorporated in both parties’ computations as sales proceeds from Excellence are the basis amounts transferred to Alofs and Target upon the exchange of Excellence shares for those in Alofs and 5 Although the stipulation refers to $5,673 as the amount from the pertinent Schedule K-1, this would appear to be a typographical error.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011