- 37 - was accounted for by those involved in the LBO transaction. In general, funds neither received by petitioners nor reported by them as income would not be considered as contributions by them to another entity such as would result in an increased basis. On this record, vague allegations of a substance that might support basis are insufficient to overcome the general rules. 4. Excellence sales price proceeds The final component specifically addressed by the parties in their stipulations regarding their respective computations of basis in Alofs and Target is the sum attributable to the Excellence shares exchanged in the LBO. As mentioned supra in our preliminary discussion concerning general computational problems, petitioners claimed a total of $2,800,000 in sales proceeds from Excellence, based allegedly on computations performed by E&Y at the time of the exchange. Mr. Gleason also testified that he “ended up surrendering my stock in Excellence for the benefit of reducing the subordinated debt by 2.8 million”, but again no operative documents from the LBO transaction elucidate this statement or the precise treatment of the Excellence shares by those involved. Respondent allowed a total of $1,427,039. To once more reprise our earlier remarks, neither calculation is adequately supported or explained by the record. No documentary evidence corroborates petitioners’ assertions, and respondent’s position is difficult to square withPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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