-3-
shall refer to Mr. England in his capacity as In Touch’s TMP as
petitioner.
The parties tried and briefed the following issues:
(1) Whether consulting fees, marketing expenses,
professional fees, and startup expenditures claimed by In Touch
on its 2000 return were properly accrued in 2000 and/or
adequately substantiated;
(2) whether promissory notes contributed to In Touch by
its members are properly included in calculating the members’
bases in In Touch; and
(3) whether promissory notes contributed to In Touch by its
members are properly included in calculating each member’s at-
risk amount under section 465(a).
For reasons explained, infra, we decide only issue (1) in
this opinion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties are incorporated herein by this
reference.
Background
In Touch is an Oklahoma limited liability company (LLC) that
was organized and formed by Lloyd Gilbert, Mark Hanna, and David
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