- 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”.                                             
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