Thomas and Janice Gleason - Page 37

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          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 with           






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