- 2 - only a small portion of that corporation’s 1999 ordinary loss and none of its 2000 ordinary loss. Scott W. Dolson and Robert C. Webb, for petitioners. Denise A. Diloreto and Mark D. Eblen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: These consolidated cases involve the following determinations by respondent of deficiencies in petitioners’ Federal income tax: Year Al A. Ruckriegel Sid Paul Ruckriegel 1999 $110,544 $107,064 2000 122,272 124,130 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts have been rounded to the nearest dollar. The issue for decision is whether petitioners had sufficient bases in their S corporation,1 Sidal Inc. (Sidal), during 1999 and 2000 (the audit years), under section 1366(d)(1)(B), to 1 The term “S corporation” is defined in sec. 1361(a)(1). In general, an S corporation has no Federal income tax liability, and its items of income, deduction, credit, and such are passed through to (i.e., taken into account by) its shareholders. See secs. 1363(a), 1366(a).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