- 15 - loans to petitioners reflect meeting dates of December 18, 1997, April 20, 1999, and November 12, 1999, the dates of petitioners’ promissory notes. Petitioners also executed partners minutes reflecting an April 1, 1997, meeting of the Paulan partners (a date prior to any of the Paulan bank borrowings or advances to Sidal or petitioners). Those minutes, in effect, provide advance authorization for any future Paulan loans to petitioners for the purpose of enabling them to relend the funds to Sidal and for those loans to take the form of direct payments to Sidal. None of the Sidal or Paulan minutes described herein (collectively, the minutes) were drafted and executed earlier than June 2000, and the minutes describing an October 31, 2000, Sidal board of directors meeting were drafted and executed sometime after October 31, 2000. Stock Basis Petitioners’ adjusted tax bases in their Sidal stock were zero as of January 1, 1999, 2000, and 2001. OPINION I. Introduction Respondent disallowed each petitioner’s deduction of his 50- percent share of Sidal’s ordinary losses for 1999 and 2000 on the ground that petitioners had zero bases for their respective investments in Sidal. Each petitioner’s basis in Sidal dependsPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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