Sid Paul Ruckriegel - Page 2

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               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).                                                     




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