- 45 - contemporaneous (and subsequent) bookkeeping for the wire transfer payments represented a further manifestation of that intent.19 As noted supra (note 7), the amounts of basis attributable to the wire transfer payments that carried over to 1999 are not certain. It is certain, however, that those basis amounts are substantially less than Sidal’s 1999 ordinary loss, thereby enabling each petitioner to deduct only a small portion of that loss and none of Sidal’s 2000 ordinary loss. We assume that the parties will be able to arrive at agreed carryover basis figures in the Rule 155 computation. E. Conclusion The Paulan direct payments did not provide petitioners with any bases in Sidal under section 1366(d)(1)(B). The wire transfer payments did provide petitioners with carryover bases in Sidal under that section sufficient to enable them to deduct a small portion of Sidal’s 1999 ordinary loss and none of Sidal’s 2000 ordinary loss. Decisions will be entered under Rule 155. 19 As in Gilday v. Commissioner, T.C. Memo. 1982-242 n.8, we regard the payments of principal and interest by Sidal directly to Paulan rather than to petitioners who, in turn, would have had to transmit those payments to Paulan, as the permissible avoidance of “fruitless steps”.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45
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